The plain-English guide to Suspicious Matter Reports

What is an SMR?

A Suspicious Matter Report (SMR) is required when a reporting entity suspects on reasonable grounds that information may be relevant to crime, a person is not who they claim to be, or a person plans to use a designated service for an AML/CTF offence.

When must you lodge?

The ordinary deadline runs from when you form the suspicion, not when the transaction settles.

1. Within 24 hours
   Terrorism-financing suspicion
   Submit an SMR within 24 hours of forming a suspicion related to terrorism financing.
2. Within 3 business days
   Other suspicions
   Submit an SMR within 3 business days after forming another kind of suspicion.

Claims involving legal professional privilege have a separate AUSTRAC timeframe and process. Check the current SMR guidance and obtain advice where that issue arises.

Indicators that may need review

No single indicator automatically means an SMR is required. Consider the complete context and follow your documented escalation process.

• Inconsistent identity information: documents or explanations that do not add up.
• Unexplained third-party funds: payment arrangements with no clear connection to the buyer.
• Unusual urgency or funding: a transaction that does not make commercial sense in the circumstances.
• Large or structured cash: physical-currency payments or behaviour that may be intended to avoid reporting.
• Opaque ownership: structures that make it difficult to establish ownership or control.

Tipping off

Do not tell a customer that you stopped services because of suspicious activity, that an SMR was submitted, or that you are required to submit one. If you are unsure how to manage a particular conversation or transaction, get professional advice before disclosing protected information.

How to handle a suspicious matter

1. Step 01
   Capture the relevant facts

   Record what happened, when it happened, who was involved, and the information or circumstances relevant to the suspicion.

2. Step 02
   Follow your escalation process

   Review the material promptly under your AML/CTF policies. Your Compliance Officer oversees and coordinates compliance, but your own policies should define who reviews and submits reports.

3. Step 03
   Submit through AUSTRAC Online

   Submit the report through AUSTRAC Online within the required timeframe. New SMR and TTR forms have applied from 1 July 2026 for newly enrolled reporting entities.

4. Step 04
   Keep supporting records

   Keep records that show your decision-making, internal escalation and compliance with reporting timeframes. Record retention periods vary, but relevant AML/CTF records are usually kept for 7 years.

SMR and TTR are different reports

• SMR: triggered by a reasonable-ground suspicion. There is no dollar threshold. The ordinary deadline is 24 hours for terrorism financing or 3 business days for other suspicions.
• TTR: triggered by a transfer of $10,000 or more in physical currency, including equivalent foreign currency. The deadline is 10 business days after the transaction.

One event can create both obligations. Treat each reporting trigger separately and follow the current AUSTRAC instructions.

SMR readiness checklist

Use this as a prompt for a proper review of your reporting process. It is not legal or compliance advice.

• My team knows how to identify and escalate suspicious activity.
• Our AML/CTF policies define timely review and reporting responsibilities.
• We can use AUSTRAC Online and the current reporting forms.
• We know when information may be protected by the tipping-off offence.
• We keep the records needed to show our reporting process and timing.

Frequently asked questions

Sources and further reading