"We Don't Take Cash" Is a Policy, Not a Fact. The $10,000 Rule Every Tranche 2 Firm Still Has.

Every professional firm we talk to says the same sentence, usually early and with some relief: "we don't take cash, so the reporting stuff doesn't really apply to us."

This week AUSTRAC suspended a business whose core failure was not filing threshold transaction reports. (What the Cryptolink suspension means for you) That was a crypto ATM operator, where cash is the whole business. But the reaction we heard from professional firms was the comfortable one: couldn't be us, we don't take cash.

The Act does not care what your policy says. It cares what happened. And "what happened" has a precise trigger with a precise deadline attached.

The Rule Itself, in Two Sentences

If, in the course of providing a designated service, a customer pays you (or you pay them) $10,000 or more in physical currency, banknotes or coins, you must lodge a threshold transaction report with AUSTRAC within 10 business days of the transaction. (AUSTRAC, threshold transaction reports)

There is no discretion in it. No suspicion is required, no judgement call about whether the client seems fine. The event happens, the clock starts, and nobody reminds you it started. It is the most mechanical obligation in the whole regime, which is exactly why AUSTRAC treats missing it as a basic failure rather than a forgivable one.

Linked Payments Count as One

The obvious reaction to a $10,000 line is to think in single payments. AUSTRAC thinks in linked transactions, and its guidance is blunt about how they add up. (AUSTRAC, examples of linked transactions)

• A client pays a $9,000 cash deposit on a $12,000 item and returns the next day with the remaining $3,000 in cash. One linked transaction, $12,000, over the line.
• A layby with a $3,000 deposit and cash instalments totalling $12,000: linked, $15,000, over the line.
• An invoice settled in three cash instalments of $4,000 over three months: linked, $12,000, over the line. There is no time limit after which linked payments reset.

The question is never "was any single envelope $10,000". It is whether the payments connect to the same item, the same sale, the same ongoing arrangement, or the same purpose.

The Structuring Twist: The Report You Don't Owe Becomes the Report You Do

Here is the part that catches firms who know about the threshold: a client who deliberately keeps payments under $10,000 so that "no report is needed" has not made your obligations go away. They have changed which obligation you have.

Transactions that look structured to avoid threshold reporting are a standing red flag in AUSTRAC's transaction monitoring guidance. (AUSTRAC, how to monitor your customers) A pattern of $9,000-ish cash payments is not a clever way for the client to spare you paperwork. It is grounds to form a suspicion, and a suspicious matter report is due within 3 business days of forming one, 24 hours if it relates to terrorism financing. (AUSTRAC, suspicious matter reports)

AUSTRAC's own worked example for jewellers describes a customer who asked a salesperson about their roster, then returned on that person's days off to make consecutive sub-$10,000 cash purchases from staff who each knew nothing about the others. The linking came from the pattern: same customer, similar items, consecutive days, always cash, always just under. (AUSTRAC, examples of linked transactions)

So the comfortable sentence inverts. If you genuinely never see cash, the TTR obligation costs you nothing. If you see cash arranged to stay under the line, you have the harder report to file, on a shorter clock.

Where Cash Actually Shows Up in a "Cashless" Practice

For dealers in precious metals and stones the question answers itself: accepting or paying $10,000 or more in cash (including linked payments) is the very thing that brings you into the regime, which is why the linked-transaction examples above are drawn from jewellery retail. (Our jeweller guide covers this end to end)

For everyone else, cash arrives at the edges, usually once a year, always as a surprise:

• A property purchaser tops up a shortfall at settlement with banknotes because a transfer did not clear in time.
• A client's parent pays the firm's invoice in cash "to keep it simple".
• A tenant hands the agency six months of rent in an envelope.
• A long-standing client of an accounting practice settles a fee from the till of their own business.

None of these people are criminals by default. That is not the point. The point is that the report is due regardless, within 10 business days, and a firm whose program says "we do not accept cash" while the front desk quietly banks an envelope has a worse problem than a missed report: a program its own records contradict.

What "We Don't Take Cash" Has to Look Like to Survive

If no-cash is your position, make it a control instead of a vibe. Four properties, none of them expensive:

1. It is written down in your AML/CTF program as a policy, with a stated threshold of zero, not assumed as culture.
2. The people who take payments know it is a rule. The partner knows; does the receptionist processing a card-declined client at 5pm on Friday?
3. There is a refusal procedure. What happens when someone opens the envelope anyway: who is told, what is recorded, whether the payment is returned. A refusal you can evidence is a control working. A quiet exception is a finding.
4. You test it. AUSTRAC's program starter kits for the new sectors ship with a TTR effectiveness check form, which tells you the regulator's expectation: not "we have a policy" but "we checked whether reality matched it".

And one more, for the day the control fails: know how you would actually lodge a TTR. The filing path through AUSTRAC Online is not hard, but 10 business days is a short runway to discover it from scratch. (Our walkthrough of SMR and TTR filing)

This Week's Version of the Check

Same discipline as the three clocks, applied to cash:

1. Ask everyone who can receive a payment one question: "what would you do if a client paid in cash?" The spread of answers is your finding.
2. Search your ledger for cash receipts in the last 12 months. If there are any, check whether any single client's receipts link to $10,000 or more.
3. Put the no-cash policy (or the TTR procedure) in writing in your program if it is not there.
4. Diarise the effectiveness check annually, same entry as your other program reviews. (How the week-to-week routine holds together)

Where AML Mate Fits

AML Mate's reports module tracks TTR and SMR deadlines from the triggering event and flags anything overdue on your dashboard, so the 10-day clock is never running silently. The program editor carries a cash-handling policy section, and the free compliance check at /check will show you in five minutes whether your reporting path exists anywhere outside the compliance officer's head.

"We don't take cash" might be true. This is the machinery that makes it checkable, and the machinery is what AUSTRAC examines.

This article is general information, not legal advice. For advice specific to your circumstances, consult a qualified AML/CTF professional.