Complete guide to submitting Suspicious Matter Reports to AUSTRAC. When to report, what to include, SMR submission process, and obligations for Australian reporting entities.
What is a Suspicious Matter Report (SMR)?
A Suspicious Matter Report is a confidential report to AUSTRAC when you suspect a customer is involved in money laundering or terrorism financing. Submitting SMRs is a legal obligation under the AML/CTF Act and protects Australia against financial crime.
When Must You Submit an SMR?
You must submit an SMR if you suspect, on reasonable grounds, that a customer or transaction is connected to money laundering or terrorism financing. Suspicion can be based on:
- Unusual transaction patterns or amounts
- Customer reluctance to provide information
- Transaction inconsistent with customer profile
- Customer from high-risk jurisdiction
- Structured transactions to avoid reporting thresholds
- Customer is politically exposed person (PEP)
- False identity documentation
- Requests to conduct suspicious transactions
SMR Submission Timeline
Deadline: Submit within 10 business days of forming the suspicion
Reporting Obligation: Do not tip off the customer that you have made a report (unless legally required)
What to Include in an SMR
Customer Information
- Full name and date of birth
- Customer identification number
- Address and contact details
- CDD documents collected
Suspicious Activity Details
- Nature of the suspicion
- What made you suspicious?
- Transaction details (amount, date, nature)
- Whether transaction was completed
Supporting Information
- Relevant correspondence with customer
- Customer background information
- Transaction history
- Any additional context
SMR Submission Process
Step 1: Internal Suspicious Activity Assessment
- Staff member identifies suspicious activity
- Report made to AML/CTF Compliance Officer
- Assess whether suspicion is reasonable
- Determine type of suspicion (ML or TF)
Step 2: Gather Supporting Documentation
- Collect customer identification documents
- Gather transaction details and receipts
- Compile communications with customer
- Document dates and times of interactions
Step 3: Prepare SMR
- Complete AUSTRAC SMR form
- Describe suspicion clearly and factually
- Include all relevant details
- Avoid conclusions without supporting facts
Step 4: Submit to AUSTRAC
- Submit via AUSTRAC secure online portal (AUS-GOVCERT)
- Alternatively: mail to AUSTRAC Intelligence Unit
- Keep copy of submission and receipt number
- Within 10 business days of forming suspicion
SMR Confidentiality
- ☐ Do not disclose to customer you have filed an SMR
- ☐ Limit internal SMR access to authorized staff only
- ☐ Store SMR securely and separate from customer file
- ☐ Retain SMR records for minimum 7 years
- ☐ Protect against tip-offs to customer
SMR Submission Checklist
- ☐ Identified suspicious matter on reasonable grounds
- ☐ Formed suspicion of ML or TF (or both)
- ☐ Within 10 business day deadline
- ☐ Gathered all supporting documentation
- ☐ Completed AUSTRAC SMR form accurately
- ☐ Included clear description of suspicion
- ☐ Submitted via secure AUSTRAC portal
- ☐ Retained copy and receipt number
- ☐ Maintained confidentiality
- ☐ Documented all SMR submissions internally
Automate SMR Submission
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