Reporting Obligations

Reporting is where a compliance program meets the regulator. Four reports apply to the firms this knowledge base covers, and they are triggered by different things, run to different deadlines, and sit in different parts of the Act.

Report	Triggered by	Deadline	Provision
SMR	A suspicion on reasonable grounds	24 hours for terrorism related, otherwise 3 business days	s 41
TTR	A threshold transaction, being physical currency of $10,000 or more	10 business days	s 43(2)
CBM	Monetary instruments of $10,000 or more crossing the border	Before customs when carrying, before sending, or 5 business days of receipt	ss 53, 54, 56
ACR	The end of a reporting period	1 July to 30 September each year	s 47

Reading this table

The deadline follows the report, not the transaction, and the trigger for one report does not imply another. A threshold transaction can require both a TTR and a suspicious matter report if the circumstances warrant it, and a cross-border movement can require a CBM from a firm that has no other involvement in the transaction at all.

Suspicious matter reports

An SMR is filed when a reporting entity forms a suspicion, or ought reasonably to have formed one, that a customer or transaction may relate to money laundering, terrorism financing, or another serious offence. The obligation is in s 41.

The threshold is suspicion, not proof. Where a reasonable person in the same position would form a suspicion, the obligation is triggered.

Deadlines run from when the suspicion was formed, under s 41(2):

• 24 hours for terrorism related suspicions
• 3 business days for all others

Where some (but not all) of the information required in the report is privileged, and the privilege belongs to someone other than the reporting entity, the non-terrorism deadline extends to 5 business days under s 41(2)(aa), and an LPP form accompanies the report. Terrorism financing stays at 24 hours regardless.

Tipping off is a criminal offence

Under s 123 of the AML/CTF Act 2006, it is an offence to disclose that a suspicious matter report has been, is being, or will be made, where the disclosure would or could reasonably be expected to prejudice an investigation.

This applies to the reporting entity and to its officers, employees and agents, not only the AML/CTF Compliance Officer. Do not tell the customer. Do not discuss it with colleagues who do not need to know. Do not leave a visible trace in a shared document, dashboard, or notification.

This is why Duely holds suspicious matter data in a separate record with its own access rule rather than as a flag on a matter, and why no suspicious matter indicator appears anywhere a non-AMLCO user can reach. The separation is the point of the feature, not a setting.

Threshold transaction reports

A TTR is required when a reporting entity provides a designated service involving a threshold transaction: physical currency of AUD $10,000 or more, received or paid out, in a single transaction. Each cash transaction is assessed on its own. If you suspect a customer is splitting cash to stay under the threshold, that calls for a suspicious matter report, and structuring is itself an offence under s 142. See AUSTRAC's Threshold transaction reports.

The deadline is 10 business days after the day the transaction takes place, under s 43(2).

Two neighbouring provisions are often confused with it:

• s 43(3)(aa) is the co-filing rule. Where information required in the report is reasonably believed to be privileged, the report must be accompanied by an LPP form.
• s 43(4) makes a failure to report within the deadline a civil penalty provision. It is not a deadline, and citing it as one is wrong.

Physical currency means coins and banknotes of Australia or a foreign country. It does not include electronic transfers, cheques, bank drafts, money orders, or card transactions.

The clock is on business days

Duely tracks the deadline on the report record and notifies the AML/CTF Compliance Officer as it approaches, rather than waiting for someone to count back from the transaction date.

Cross-border movement reports

A CBM is required when monetary instruments with a combined value of AUD $10,000 or more are moved into or out of Australia. Monetary instruments means physical currency and bearer negotiable instruments, such as bearer cheques, bearer bonds, travellers cheques, and money orders payable to bearer.

This obligation applies even where the movement is unrelated to a designated service, which is the part most firms miss. All reporting entities must report qualifying movements.

The deadline depends on the situation rather than the direction:

Situation	Deadline
Carrying instruments through customs, arriving or departing	Before passing through customs
Mailing or shipping into or out of Australia	Before sending (Rules 9-12(3)(b) covers inbound)
Receiving instruments from outside Australia	Within 5 business days of receipt

An inbound traveller carrying instruments reports before customs, not within 5 business days. The 5 business day window applies to instruments received from outside Australia.

Electronic transfers are excluded from CBM. Section 46 now covers reports of international value transfer services, and IFTI reporting continues under transitional rules. Those reports fall on the institution sending or receiving the transfer rather than on a professional services firm.

Annual compliance reports

Unlike the other three, the ACR reports on the firm's compliance with its obligations over a period, rather than on a single transaction or suspicion. The obligation is in s 47, with the periods set in the AML/CTF Rules.

Every reporting entity is on a financial year reporting period, with the report covering the previous financial year of 1 July to 30 June. The submission window is 1 July to 30 September each year.

For a Tranche 2 firm, the first report covers the 2026 to 2027 financial year and is due by 30 September 2027.

AUSTRAC's guidance for each report type is at Suspicious matter reports, Threshold transaction reports, Cross-border movement reports and Annual compliance reports.

Not 31 March

Some older material states the ACR is due by 31 March. That was the previous calendar year schedule, and it does not apply to a Tranche 2 entity whose obligations began on 1 July 2026. Do not rely on the earlier date.

How reporting works in Duely

Duely prepares the report record, and the firm lodges it with AUSTRAC. There is no direct submission rail. For suspicious matters, Duely produces the AUSTRAC XML payload and the AML/CTF Compliance Officer files it through AUSTRAC Online, recording the response reference back against the case.

Step	Working by hand	In Duely
Knowing a deadline applies	Counted from a transaction date on a calendar, or noticed when someone asks.	The deadline is calculated when the record is created, and the AML/CTF Compliance Officer is notified as it approaches.
Building the report	Assembled at the end from emails, statements, and whatever the customer file holds.	Drawn from the matter record, so the customer details and verification history are already attached.
Preparing the lodgement	Re-keyed into AUSTRAC Online from a working document.	Suspicious matter reports export as an AUSTRAC XML payload; the officer files it and records the reference back.
Showing what was decided	A sent email and a copy in a folder, if both survived.	The decision, its rationale, and the person who made it are recorded and retained with the matter.

Report records for threshold, cross-border and suspicious matters live in different places by design. Suspicious matter reporting is AMLCO-only, so it does not appear among the other report records.

The report records register, showing draft records and their tracked deadlines.

Related pages

• Customer due diligence, because customer monitoring is what surfaces most suspicions.
• Record keeping, for how long reports and their working papers must be kept.
• Review and evaluation, for the effectiveness testing that checks whether reporting works.
• Filing a report, for the product walkthrough.