What are the reporting obligations to AUSTRAC?

Suspicious Matter Reports ("SMRs")

All reporting entities are required to submit SMRs to AUSTRAC where they suspect, on reasonable grounds, that:

Information the reporting entity holds may be relevant to a crime
A person is planning a money laundering ("ML") or terrorism financing ("TF") offence using a designated service
A customer, potential customer or their agent is not who they claim to be

This includes where a reporting entity suspects on reasonable grounds that it has information that concerns ML, TF or offences such as tax evasion or other Commonwealth, state or territory offences.

Reasonable grounds is an objective standard, which means that reporting entities must consider whether a reasonable person, in their position and with the same facts, circumstances and information available, would form a suspicion.

The timing of lodgement of SMRs is very short. SMRs must be submitted to AUSTRAC:

  • Within 24 hours where the suspicion relates to terrorism financing;
  • Within 3 business days where the suspicion relates to money laundering or other serious crime.

International Funds Transfer Instructions ("IFTIs")

There are two types of IFTIs:

  • an instruction accepted in Australia for money or property to be made available in another country, or
  • an instruction accepted in another country for money or property to be made available in Australia.

 

There are two types of IFTI reports that can be submitted to AUSTRAC:

  • IFTI-Es – required where financial institutions transfer money to or from another country
  • IFTI-DRAs – required where remittance service providers, casinos and other entities that are not financial institutions transfer money or property.

 

Where a reporting entity receives instructions to transfer money or property, it must provide a report to AUSTRAC. AUSTRAC Online gives reporting entities the ability to report bulk transactions. IFTI reports are due within 10 business days of receiving the instruction.

Note: The Anti‑Money Laundering and Counter‑Terrorism Financing Transitional Rules 2026 preserve the operation of the pre‑31 March 2026 IFTI reporting requirements.

This means reporting entities must continue submitting IFTI reports until the international value transfer service (“IVTS“) reporting transition date, which will be on or after 31 March 2029.

Threshold Transactions ("TTRs")

Where a reporting entity provides a designated service that involves transfers of $10,000 or more in physical currency, it must make a threshold transaction report to AUSTRAC. The transfer can include receiving or paying cash and the $10,000 threshold applies to the foreign currency equivalent.

The report is due to AUSTRAC within 10 business days of the transaction.

Annual Compliance Reports

All reporting entities (except item 54 providers) must lodge an annual report with AUSTRAC which provides AUSTRAC with details about how the entity has complied with its AML/CTF obligations throughout the year. The reporting period is 1 July – 30 June.

Annual compliance reports are due to AUSTRAC within 3 months of the end of the financial year. Submissions of the annual compliance report can be made via AUSTRAC Online from 1 July each year. The submission window closes on 30 September.

Reporting entities which are part of a reporting group are only required to submit one annual compliance report. It is the responsibility of the lead entity to lodge the report on behalf of all members of the group. However, any group member can elect to lodge their own report if the information to be provided to AUSTRAC differs substantially from the other members of the group.

Note: there are other reporting obligations that we have not included on this page, which may apply to you, such as cross-border movement reports. Further detail can be found on AUSTRAC’s website.

AML/CTF Reforms

Sophie Grace can provide you with an AML/CTF Program and can assist you to tailor it to your business’ needs. We have three different options available to suit your business and finance needs.

Template Documents

You can purchase template documents from our online shop. The template is an instant download and includes prompts to help you tailor the document yourself. We have template documents for:

  • Tranche 1 Reporting Entities;
  • Item 54 Providers; and
  • Tranche 2 Entities.
Compliance Portal

Sign up to the Compliance Portal and receive the template AML/CTF Program Package, and obtain access to updated documents in light of any updates we make as new guidance or amended legislation is released. Choose between:

  • document-only plans;
  • consultation-only plans;
  • video and regulatory update plans; or
  • a combination of all three.
Tailored Documents

Sophie Grace can assist you to prepare the AML/CTF Program package based on your business’ specific requirements. Contact us to discuss further. 

Find everything you need in relation to the AML/CTF Reforms

Sophie Grace Compliance Portal

Sign up today for up-to-date compliance policies and regular consultation with our staff. Watch our demonstration video now!

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