Are EFT payments and PEXA settlements covered by the TTR threshold?

No. TTRs apply to physical currency. Bank transfers, electronic conveyancing payments, and trust account EFT deposits are not cash.

What if a single matter is both suspicious and a cash transaction over $10,000?

File both. The SMR clock (24 hours / 3 business days) applies to the suspicion; the TTR clock (10 business days) applies to the cash.

Disclosing — to the customer or anyone else — information that would prejudice an investigation into the matter you reported. The reform from 31 March 2025 made it an outcome-focused test rather than strict liability. Penalty: up to 2 years' imprisonment, 120 penalty units, or both.

Do we need to document SMRs we decide not to file?

Yes. The decision trail is the defence. Record the matter, the analysis, and the reasoning.

SMRs and TTRs

Suspicious matter reports and threshold transaction reports — the deadlines, the triggers, the tipping-off rule, and how the two overlap in real estate.

In short

SMRs go in within 24 hours for terrorism financing suspicions and 3 business days for other suspicions (5 business days where legal professional privilege is in play). TTRs cover physical cash of AU$10,000 or more and have a 10-business-day deadline. Tipping off is a separate offence carrying up to two years' imprisonment.

Two reports do most of the work under the Act: the suspicious matter report (SMR) and the threshold transaction report (TTR). They sit alongside an offence — tipping off — that polices what you say after you file.

SMRs (Act s 41). Triggered when a reporting entity forms a suspicion on reasonable grounds about a customer or transaction relating to money laundering, terrorism financing, proliferation financing, proceeds of crime, tax evasion, or relevant Commonwealth offences. Real estate triggers in practice: implausible source of funds, third parties paying the deposit without explanation, urgent off-market settlements involving unusual structures, or buyer behaviour that doesn't match the documentation.

Deadlines:

Terrorism financing suspicions — 24 hours from forming the suspicion (the LPP extension below does NOT apply to TF)
All other suspicions — 3 business days from forming the suspicion
5 business days where legal professional privilege is in play — non-TF suspicions only, and only where privilege belongs to a client rather than the reporting entity

Lodge through AUSTRAC Online. The narrative section matters: include the grounds for suspicion, the parties, the transactions, and the supporting evidence. AUSTRAC reads narratives.

TTRs (Act s 43). Triggered by a transaction involving physical currency (or e-currency) of AU$10,000 or more — or the foreign currency equivalent. Bank transfers, cheques other than cash cheques, EFT deposits to the trust account, and PEXA settlements are not cash transactions. The threshold targets physical notes and coins.

In real estate, the realistic scenarios are:

A buyer pays a deposit in physical cash at the agency
A buyer presents cash at any point in the transaction
A series of cash payments that aggregate to AU$10,000 or more and appear connected (structuring) — almost always also an SMR

Deadline: 10 business days from the transaction. Lodged through AUSTRAC Online.

A TTR is a factual report and does not imply suspicion. Where a transaction is both threshold and suspicious, both reports are required; the SMR deadline (24 hours or 3 business days) applies to the suspicion element.

Tipping off (Act s 123). From 31 March 2025, tipping off changed from a strict-liability offence to an outcome-focused test: did the disclosure prejudice, or risk prejudicing, an investigation? Penalty: up to 2 years' imprisonment, 120 penalty units, or both. Real-estate examples to avoid: telling the buyer their CDD pack has been escalated, telling a vendor why the agency declined to act, telling staff in earshot of customers that "AUSTRAC has been notified."

Best practice. Most agencies will adopt a written "no cash" policy for deposits and settlements. The policy reduces TTR volume but does not eliminate the obligation — if cash is presented and accepted, the report still must be filed. Document every SMR decision, including decisions not to file. The decision record is what defends the call when AUSTRAC asks.

What to do next. Adopt a written cash-handling policy. Brief every agent on the SMR and TTR deadlines and the internal escalation path. Make sure every staff member knows what tipping off looks like and why it is the rule least likely to be excused by inexperience.

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Frequently asked questions

Are EFT payments and PEXA settlements covered by the TTR threshold?: No. TTRs apply to physical currency. Bank transfers, electronic conveyancing payments, and trust account EFT deposits are not cash.
What if a single matter is both suspicious and a cash transaction over $10,000?: File both. The SMR clock (24 hours / 3 business days) applies to the suspicion; the TTR clock (10 business days) applies to the cash.
What is tipping off?: Disclosing — to the customer or anyone else — information that would prejudice an investigation into the matter you reported. The reform from 31 March 2025 made it an outcome-focused test rather than strict liability. Penalty: up to 2 years' imprisonment, 120 penalty units, or both.
Do we need to document SMRs we decide not to file?: Yes. The decision trail is the defence. Record the matter, the analysis, and the reasoning.

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