Reporting obligations

From 1 July 2026, reporting obligations under the AML/CTF regime will apply.

Suspicious Matter Reports (SMRs)

You must submit an SMR within 3 business days if, in providing a designated service, you have reasonable grounds to suspect (or know) that:

  • A person is not who they claim to be, or
  • A matter may be linked to criminal activity or proceeds of crime.

If the suspicion relates to terrorism financing, the report must be submitted within 24 hours of the suspicion arising.

Note: This is an objective test based on “reasonable grounds to suspect” — not certainty.

Threshold Transaction Reports (TTRs)

Submit a TTR within 10 business days for any cash transaction of A$10,000 or more involving a designated service.

International Value Transfer Service Reports

Submit a report within 10 business days for any international transfer of value connected to a designated service.

Transfers Involving Unverified Self-Hosted Virtual Asset Wallets

If your designated service involves receiving virtual assets from an unverified self-hosted wallet, a report must be submitted within 10 business days.

Cross-Border Movement Reports

These reports apply to individuals carrying A$10,000 or more in cash or bearer negotiable instruments into or out of Australia. They apply at the border to the person physically carrying the currency or instrument — not the law practice.

Annual Compliance Reports

You’ll need to submit an annual compliance report summarising how your practice met its AML/CTF obligations for the previous calendar year. This report must be lodged within three months after the end of each reporting period.