Reporting obligations

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.

Practitioners who submit an SMR cannot disclose any information about that report to the client, where such disclosures would prejudice an investigation or potential investigation (s123). This is known as “tipping off”.

Practice Tip:

To avoid tipping off, consider:

• initially reporting the issue internally as an “unusual activity” (as opposed to a SMR) to the Compliance Officer to ensure timeframes have not yet been activated.
• not making this report by a standard email as this may automatically go on the client’s file which could be accidentally handed over to the client at the conclusion or transfer of the matter.
• ensuring all internal communications about an SMR must be kept separate from the client’s file.

If you are concerned that your client’s activities might trigger an SMR, please contact the QLS Ethics and Practice Centre to discuss how to manage your professional and ethical obligations.

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.