2026-07-01
Added
Entities providing designated services, excluding remittance network services, must submit Suspicious Matter Reports via AUSTRAC Online within 24 hours for terrorism financing suspicions, 3 business days for others, or 5 business days if claiming legal professional privilege. Reports must detail the suspicion, involved parties, and transactions, including virtual assets. Entities must not tip off customers or disclose the report. Enhanced customer due diligence is required if services continue, but submission must not be delayed to complete it. Sharing SMR details that could prejudice an investigation is a criminal offence.
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SMRs alert authorities to potential money laundering, terrorism financing, proliferation financing and other crime. It’s vital your SMRs are accurate and timely to help combat crime and protect our community.
This guidance will help you:
This section refers to the Act sections 41 and 30(2) and the Rules section 9-3.
You must submit an SMR to us if you suspect on reasonable grounds that:
This includes where you suspect on reasonable grounds you have information that concerns:
Reasonable grounds is an objective standard. This means that a reasonable person in your position would form a suspicion based on the facts, circumstances, and information available.
This includes all the information and circumstances that you know or could reasonably be expected to have known at the time.
A ‘reasonable person’ is a legal term. It refers to a hypothetical person who displays reasonable or ordinary behaviour or judgment in the circumstances.
We expect that you understand and explain your suspicion in a way that demonstrates a reasonable person would likely reach the same conclusion where they:
You must monitor unusual transactions and customer behaviour for activity which may trigger an SMR.
Learn more about monitoring your customers’ transactions and behaviours in ongoing customer due diligence (CDD).
You must submit an SMR (through your AUSTRAC Online account) even if you can’t identify the offender or suspected victim. Learn more about submitting reports through AUSTRAC Online.
SMR obligations apply when you start or propose to provide a designated service, or someone asks for a designated service.
The obligation applies even if you don’t end up providing the designated service to your customer. This is because criminals may ‘test the market’ to find vulnerabilities with certain providers.
Examples of when to submit an SMR include if a customer:
You must submit an SMR to us each time you form a new suspicion on reasonable grounds. This applies even if you’ve already reported someone. You should include reference numbers for any previous SMRs on the same customer. This helps us identify patterns of behaviour and activity.
For example, you might submit a report because you suspect on reasonable grounds that a customer is structuring their transactions. If the customer returns to request further transactions that raise reasonable grounds for suspicion, submit a separate SMR and include the reference number for any previous related SMRs.
This section refers to the Act sections 42(5), 41(2A) and 41(3).
You don’t have to submit an SMR to us if you:
If you believe only some information about your suspicion in your SMR is protected by LPP, and you intend to withhold it, you must submit an:
Learn more about legal professional privilege.
This section refers to the Rules section 9-10(2).
Remittance network provider (RNP) affiliates must also submit SMRs. However, with written agreement, either the affiliate or RNP can make the report.
This section refers to the Act sections 41(2)(a)-(b).
You must submit the SMR to us within:
When you claim the SMR includes information protected by LPP you have up to 5 business days after the day you form the suspicion to submit the SMR to us. This includes if part of the information is privileged and belongs to someone other than the reporting entity. This timeframe doesn’t apply if your suspicion relates to terrorism financing.
Submit SMRs through AUSTRAC Online.
We’ve published a range of resources to help you submit, including:
This section refers to the Rules sections 12-1 and 12-2.
The SMR form you use depends on when you enrolled with us.
If you enrolled after 30 March 2026, you must use the new SMR form from 1 July 2026.
If you were enrolled with us on 30 March 2026, you can transition to the new SMR form any time between 1 July 2026 and 30 March 2029. During this period you can choose to:
Your anti-money laundering and counter-terrorism financing (AML/CTF) policies must help you:
What’s timely depends on the level of risk. We expect you to prioritise reviewing and responding to higher risk matters more urgently. This includes suspicious activity that could have a significant impact or cause major damage. For example:
To make sure your submissions are timely, we expect your AML/CTF policies to:
We generally expect all customer facing personnel to be trained in recognising suspicious activity and referring it to the appropriate person in your business.
The individual or team responsible for assessing this suspicious activity and submitting SMRs could then be either:
You should also consider how to avoid ‘information silos’. This means personnel investigating SMRs can quickly access information they need. Include processes to make sure you report within the required timeframes.
We expect you to design your AML/CTF program to identify and include:
Learn more about:
These common indicators of ML/TF and other serious crimes can help you identify suspicious activity.
One indicator on its own may not amount to suspicious activity. There may be legitimate reasons for the behaviour or transactions.
Multiple indicators may be required depending on the circumstances.
The customer:
The customer:
The customer:
Once you’ve identified suspicious activity, you must review that activity and relevant information to determine whether you have reasonable grounds for suspicion.
We expect you to:
If you form a suspicion on reasonable grounds at any point, you must submit an SMR to us within the required timeframe. You don’t need to be certain that a crime has occurred.
This section refers to the Rules sections 5-12(a)-(b).
Your policies must help you to conduct a timely review of material when deciding whether to submit an SMR.
To help decide, you may consider:
This section refers to the Act sections 30(2)(a) and 111.
We expect you to take appropriate action after your initial assessment.
| Outcome | Action |
|---|---|
| You decide there’s no reasonable grounds for suspicion | You may choose to make a written record of the reasons for the decision. These records can be used if there’s more suspicious activity by the same customer. It will help you to better understand your customer’s behaviour if you need to consider whether to submit an SMR in future. It also demonstrates you’re monitoring customers for unusual transactions and behaviour. No further action required. |
| After an initial assessment, you’re still suspicious, but you don’t have enough information to confirm reasonable grounds | We expect you’ll continue to monitor the customer, conduct further investigations where required and keep written records of any steps taken in relation to the suspicion. If you don’t, you may not meet your obligation to monitor customers for unusual transactions and behaviour that could lead to an SMR. |
| You decide you have reasonable grounds for suspicion | You must submit an SMR within the appropriate timeframe. If you continue providing the designated service, you must conduct enhanced CDD in line with your AML/CTF policies. |
This section refers to the Act sections 32(b) and 41(2).
You must conduct enhanced CDD if both of the following occur:
If you've applied enhanced CDD previously on the customer, we expect that you include a summary of the enhanced CDD and what it showed in your SMR.
You must not delay submitting your SMR to complete enhanced CDD if you already have already formed a suspicion on reasonable grounds.
This section refers to the Rules sections 9-2, 9-3 and 9-4.
Your SMR must include details of:
If used in the transaction, your SMR must also include information about:
Learn more at Division 1 of Part 9 of the Anti-Money Laundering and Counter-Terrorism Funding Rules (the Rules).
The information above differs from what you currently need to provide in an SMR and you’ll need to provide it in a new SMR form (this will be available before the laws start).
Your SMR must include a description of the grounds for your suspicion.
An effective grounds for suspicion clearly explains:
In the first sentence you may consider including a high-level summary of the suspicious activity and indicators for your suspicion.
After a summary, you may consider providing:
You could also consider summarising:
Include as much detail as possible. Your insights and expert knowledge help make your SMRs more valuable.
When providing information about the person, this could include:
If you have limited information about someone’s identity, your SMR could instead include:
You may:
Example 1
‘Customer A requested to transfer money to Person B using what staff thought was a false ID.’
Example 2
‘Customer C bought $15,000 worth of cryptocurrency and transferred it to Person D’s crypto wallet. The activity is inconsistent with their usual account use. When questioned, Customer C didn’t know basic details about Person D and said they were just helping a friend.
We suspect Person D may be part of a fraud or money laundering scheme.’
These examples clearly state the:
Your SMR would then include the indicators you identified.
Example 1
‘Customer A’s activity is considered suspicious.’
Example 2
‘Customer C made a transaction that looked unusual and we’re submitting this report just in case it might be suspicious.’
These examples don’t contain any specific details about:
You shouldn’t assume we have knowledge of the individual or activity. Always provide complete details, and make sure your report is correct and complete.
We expect you to use generally known acronyms. We’re unlikely to know:
We ask that you don’t include the following information in reports you submit to us.
The Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (the Act) doesn’t authorise you to disclose TFNs to us.
You don’t have to end your relationship with a customer if you submit an SMR. You can continue to provide them with designated services.
However, you must appropriately mitigate or manage any ML/TF risks. This includes applying enhanced CDD.
For high-risk customers, controls to mitigate or manage the risk could include:
If you decide to stop providing designated services to a customer, you must not:
It’s a criminal offence to share SMR details if it could reasonably prejudice an investigation.
Learn more about tipping off.
Below are 2 examples of timely and quality SMRs.
An RNP’s transaction monitoring system alerts their financial crime analyst to several transactions made by the same customer. The system identified a customer sending 5 payments within 3 months to an individual in another country. This country has a high child exploitation risk.
The payments were all valued between $50 and $250, with payment descriptions of ‘family support’.
Small financial transactions to high-risk countries are financial indicators of sexual exploitation of children.
Staff contact the customer who says the payments are for his family who live overseas.
Noting the risk of child sexual exploitation, the analyst conducts enhanced CDD according to their AML/CTF policies and a review of transactions. They also do internet searches, including social media.
The investigation finds:
This information gives the AML/CTF compliance officer reasonable grounds for suspicion. They submit an SMR within 3 business days.
A bank’s transaction monitoring system flags 12 cash deposits in a month from a single customer. All transactions are between $7,000 and $9,900.
A member of the financial crime team does an initial assessment. They find the customer doesn’t normally make cash deposits. They identify other indicators of suspicious activity. This includes the customer:
The staff member investigates the customer's source of funds and source of wealth. The customer claims the cash is from their salary.
The staff member believes there are indicators the customer may be a money mule and is structuring payments. The staff member believes the customer is laundering proceeds of crime on behalf of a criminal network.
The bank decides there are reasonable grounds for suspicion and submits an SMR within 3 business days.
This guidance sets out how we interpret certain Australian legislation, along with associated Rules and regulations. Australian courts are ultimately responsible for interpreting these laws and determining if any provisions of these laws are contravened.
The examples and scenarios in this guidance are meant to help explain our interpretation of these laws. They’re not exhaustive or meant to cover every possible scenario.
This guidance provides general information and isn't a substitute for legal advice. This guidance avoids legal language wherever possible and it might include generalisations about the application of the law. Some provisions of the law referred to have exceptions or important qualifications. In most cases your particular circumstances must be taken into account when determining how the law applies to you.
Last updated:
9 Sep 2026
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Source: Australian Transaction Reports and Analysis Centre — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works
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