From 1 July 2022, TTRs must be submitted to AUSTRAC for each individual cash transaction of $10,000 or more. Reporting Entities are no longer required to combine customer transactions totalling $10,000 or more and submit a combined TTR even if the transactions are close together.
If a Reporting Entity has a suspicion that a customer is attempting to split a large sum of cash transactions into multiple smaller transactions (also known as ‘structuring’) to avoid AUSTRAC reporting obligations, a suspicious matter report must be submitted to AUSTRAC.
As AUSTRAC recognises the implementation of the updated guidance on TTRs will require Reporting Entities to update their systems and processes, AUSTRAC is providing a 12 month transition period to ensure compliance with the obligations.
Sophie Grace recommends Reporting Entities start implementing the necessary changes to stay compliant with TTR obligations. Reporting Entities should also consider the requirement for any staff training in light of the amendments to TTR obligations.
If you need assistance with compliance needs, please contact Sophie Grace.
Part 3, Division 3 (Sections 43 and 44) of the AML/CTF Act (latest version) – Threshold transactions
Chapter 19 of the AML/CTF Rules (latest version) – Reportable details for threshold transactions