How to File a Suspicious Matter Report (SMR) with AUSTRAC: A Step-by-Step Guide for Professionals
An SMR must be filed with AUSTRAC whenever you suspect a client or transaction is connected to money laundering or terrorism financing. This guide covers when, how, and what to include — plus the critical tipping-off rules.
What is a Suspicious Matter Report (SMR)?
An SMR is a mandatory disclosure to AUSTRAC when you know, suspect, or have reasonable grounds to suspect that: - A designated service relates to proceeds of crime - A person is engaged in money laundering - A person is engaged in terrorism financing - Providing the service would result in committing a financial crime From 1 July 2026, accountants, lawyers, conveyancers and real estate agents are required to file SMRs.
What triggers an SMR?
AUSTRAC requires only reasonable grounds for suspicion — not certainty. **Accountants**: Client structures transactions to avoid reporting thresholds; unexplained wealth; refusal to provide identity or source-of-funds information; complex entities formed for unclear purposes. **Lawyers**: Large cash payments for property; funds held for unusually short periods; transactions with no apparent commercial purpose; evasion about source of funds. **Real estate agents**: Cash purchases; multiple unrelated bank accounts; property sold significantly above/below market; client refuses identity verification.
SMR timing requirements
| Situation | Deadline | |-----------|----------| | Terrorism financing suspicion | 24 hours from forming suspicion | | All other suspicions | 3 business days from forming suspicion | The clock starts when you **form** the suspicion — not when you have completed investigation. Do not delay to gather more evidence. You are protected from civil liability for a good-faith SMR.
The tipping-off prohibition — Critical rule
Section 123 of the AML/CTF Act 2006 prohibits disclosing: - That you have filed (or are considering filing) an SMR - Any information indicating a person is the subject of an SMR **Applies to disclosures to**: the client, their associates, other businesses, and colleagues outside the need-to-know chain. **Penalties**: Up to 2 years imprisonment and/or fine. If a client asks "are you reporting me?", you cannot confirm or deny. State that identity verification is a mandatory legal requirement.
How to file an SMR with AUSTRAC
**Step 1** — Document suspicion internally: facts, date formed, basis for suspicion, designated service involved. **Step 2** — Log in to AUSTRAC Online (portal.austrac.gov.au). **Step 3** — Complete the SMR form: reporting entity details, persons involved, description of suspicious matter, date and nature of transaction. **Step 4** — Submit and retain confirmation + reference number for 7 years. **Step 5** — Continue services with caution. Do NOT disclose the SMR to the client.
Retaining SMR-related records
Even if you decide NOT to file an SMR, document: - The matter that gave rise to suspicion - Your investigation - Reasons for not filing All non-filing decisions must also be retained for 7 years. AUSTRAC can request these records during inspection to verify your decision-making standards.