AUSTRAC AML/CTF Requirements
Suspicious Matter Reports (SMRs) are one of the most important AML/CTF obligations. This guide explains what triggers an SMR, when to report, and how to stay compliant under Tranche 2.
An **SMR** is a mandatory report to AUSTRAC when you suspect that a customer or transaction may be linked to:
You do **not** need proof — only a **reasonable suspicion**.
You suspect the customer is not who they claim to be
The transaction has no clear business or legal purpose
The customer refuses to provide identity documents
The customer is evasive or provides inconsistent information
The transaction is unusually large or complex
The customer is linked to a high‑risk jurisdiction
You detect unusual patterns or behaviour
If you suspect something is wrong, you must lodge an SMR — even if the transaction does not proceed.
Must be lodged within 3 business days of forming a suspicion.
Must be lodged within 24 hours.
Customer avoids answering basic questions
Large cash transactions
Structuring transactions to avoid reporting
Unusual property purchases
Use of third parties or intermediaries
Rapid movement of funds
High‑risk jurisdictions
Unexplained wealth
Negative media or criminal associations
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