How to Submit a Suspicious Matter Report (SMR) to AUSTRAC

What is a Suspicious Matter Report (SMR)?

A Suspicious Matter Report is a confidential report you file with AUSTRAC when you reasonably suspect that a person or transaction is linked to criminal activity. SMRs generate crucial intelligence that helps law enforcement identify, investigate, and disrupt money laundering, terrorism financing, and other serious crimes.

For reporting entities, the obligation relates to a designated service you provide, propose to provide, or are asked about providing. A transaction does not have to be completed. Subject to applicable exemptions, you must submit an SMR if you have reasonable grounds to suspect that:

• A person is involved in money laundering or terrorism financing
• A transaction relates to criminal activity
• A customer, prospective customer or their agent is not who they claim to be
• Information you hold may be relevant to the investigation or prosecution of a person for an offence against a Commonwealth, State, or Territory law
• A person is a victim of crime (for example, identity fraud)

You do not need to prove that crime has occurred. A “reasonable suspicion”, based on the facts available to you, is sufficient.

Wondering whether these obligations reach your practice, and what the clock would look like in real dates? The free check helps you assess whether your services may be covered, lists the suspicious activity indicators AUSTRAC publishes for your sector, and dates the report that a suspicion formed today would trigger. No signup.

When must you report?

Filing deadlines depend on the nature of the suspicion:

• Within 24 hours of forming the suspicion if it relates to terrorism financing
• Within 3 business days after the day the suspicion formed for other matters, subject to the LPP exception below

For the standard deadlines, including the public holidays in your state, use the SMR and TTR deadline calculator.

The clock starts when the suspicion is formed, not when the transaction occurred. If you become suspicious about a transaction days or weeks after it happened, you must report within the timeframes above. Do not postpone assessing unusual activity to delay the start of the reporting period.

Penalties for not reporting

Failing to submit an SMR within the required timeframe can result in civil penalties imposed by a court of up to 20,000 penalty units for individuals or 100,000 penalty units for body corporates. AUSTRAC can also require you to provide additional information. Failure to comply with those requirements can attract further penalties.

Sources: AUSTRAC SMR guidance and AML/CTF Act, sections 41 and 175.

How to identify suspicious matters

Suspicious activity can take many forms depending on your industry. While no single indicator guarantees criminal activity, the following should prompt a timely review of the facts and possible legitimate explanations:

Client behaviour

• Client is unusually secretive, evasive, or nervous when asked routine questions
• Client avoids face-to-face meetings or identity verification
• Client appears to be acting on instructions from someone else
• Client ends the relationship when asked for standard compliance information
• Client has an unusual level of knowledge about AML/CTF reporting thresholds

Transaction patterns

• Transactions inconsistent with the client's known business or personal profile
• Large cash payments with no clear source of funds
• Transactions structured to fall just below reporting thresholds (suspected structuring)
• Rapid movement of funds between accounts with no apparent business purpose
• Transactions involving high-risk jurisdictions with no logical connection to the client's business

Identity concerns

• Identity documents appear forged, altered, or in an unexpected format
• Client provides inconsistent personal details across different interactions
• Multiple people share the same address, phone number, or bank account with no apparent relationship

For industry-specific indicators, see our Suspicious Activity Indicators page.

Step-by-step submission process

Businesses enrolled after 30 March 2026 must use the new SMR form. Businesses already enrolled on 30 March 2026 can transition between 1 July 2026 and 30 March 2029.

Step 1: Document the suspicion

Before logging into AUSTRAC Online, gather all relevant facts. Write down why the behaviour or transaction is suspicious in plain English. Include the five W's: who is involved, what happened, when it occurred, where it took place, and why you consider it suspicious. Record when the suspicion formed and include a summary of any enhanced CDD already performed and what it showed. Report on time even if further checks are continuing.

Step 2: Log into AUSTRAC Online

Open AUSTRAC Online and sign in using your business reporting access.

Step 3: Create the SMR

For the new form, choose Reporting, then Make a Report, Report SMR and Start single report. Use the linked tutorial for the portal screens.

Step 4: Complete the required fields

Follow the form applicable to your business. The new form adapts to your answers: list the parties before adding their associations and related transactions.

• People involved: Enter the identifying details you hold, including names, addresses, dates of birth and relevant documents. Identify each person's role and distinguish victims from suspects. Describe unknown subjects using the information available; do not invent missing details.
• Transaction and service details: Record the relevant dates, amounts, accounts and activity. An SMR can be required even when the proposed transaction did not proceed.
• Grounds for suspicion: Write a clear, factual explanation of why you are suspicious. Use plain English with a logical structure. Separate what you observed from your inferences and support those inferences with the facts.

Legacy form: If you are eligible and still using the pre-July 2026 form, Part C covers the suspicious person and Part D covers other parties, including victims. These labels are legacy instructions, not universal section names for the new form.

Step 5: Review and submit

Check all details for accuracy. A high-quality SMR is clear, concise, complete, and submitted on time. AUSTRAC uses your report to generate intelligence for law enforcement. The better your report, the more useful it is. Complete the portal submission and retain the receipt available from its reporting dashboard. A saved draft is not a lodged report.

Common mistakes to avoid

• Too vague: “Client seemed suspicious” is not enough. Explain what specifically was suspicious: unusual transaction amounts, inconsistent documents, evasive behaviour.
• Missing the deadline: Apply the correct deadline, including any valid LPP exception. Set up internal procedures to escalate suspicions immediately.
• Confusing victim and suspect: Identify the person's role accurately. In the legacy form, victims belong in Part D and the suspicious person in Part C. For the new form, follow its party-role prompts.
• Including unverified details in the wrong section: Use the appropriate party fields for the details you hold and explain what remains unknown. Do not substitute a victim's identity for an unknown suspect.
• Not filing because you're “not sure”: You don't need certainty. A reasonable suspicion is sufficient. Assess the facts promptly and explain your grounds; do not submit a report solely because an unexplained indicator appeared.

Tipping off: a criminal offence

Tipping off is a criminal offence where disclosure of protected information would or could reasonably be expected to prejudice an investigation. This can include revealing an SMR or that the reporting obligation has arisen. Consider the effect on a current or future investigation, even if you do not know one exists.

Protect the information throughout preparation, submission and follow-up:

• Do not tell a client or associate about the report in a way that could alert them to an investigation or help them hide activity.
• Keep reports and related records accessible only to people with a genuine need to know.
• Before sharing with staff, your compliance officer, a legal adviser or another recipient, assess what will be disclosed, why, and the risk of further disclosure.
• Use your approved customer communication procedures and seek advice when the consequences of a disclosure are uncertain.

Some disclosures to manage ML/TF risk or obtain legal advice will generally not breach the offence, but this is not blanket permission. Privacy and other legal restrictions still apply.

The provisions protect investigations from evidence being destroyed or activity being concealed. See AUSTRAC's current tipping off guidance for the test, exceptions and examples.

Real case studies

These real-world examples from AUSTRAC demonstrate the impact of SMRs:

• Drug syndicate dismantled: An SMR was key to identifying individuals, financial transactions, and establishing links between syndicate members, leading to two convictions.
• International cybercriminal captured: SMRs identified an offender operating multiple false-name accounts and moving large unexplained cash. The person turned out to be a US-wanted fugitive for cybercrime and fraud.
• Child exploitation disrupted: Financial transaction reporting from four entities, with SMRs from two of them, uncovered suspicious fund flows to high-risk jurisdictions, helping law enforcement target offenders.
• Welfare fraud exposed: SMRs prompted a police investigation into a couple with unexplained wealth, resulting in three arrests, $100,000 in cash seized, and disruption of a drug supply network.

Your SMR, even if it seems minor, can be the piece of intelligence that triggers or supports a major investigation.

How AML Mate helps with SMR reporting

• Client pre-fill: Select a client to copy available subject details. Review those details and enter the relevant transaction information.
• Step-by-step wizard: Work through Suspicion, Transaction, Subject, Assessment and Review, with prompts for grounds and actions taken.
• Form checks: Review missing fields and advisory content checks before marking a report ready. These are not complete AUSTRAC lodgement validation.
• Deadline tracking: View the recorded standard deadline and report status. Check any special legal circumstances separately.
• Report records: Keep drafts and exports, then record your AUSTRAC reference after lodging.
• Suspicious activity indicators: Consult the general and industry-specific reference cards when reviewing unusual activity.

You lodge the report in AUSTRAC Online. Saving, exporting or marking an SMR ready in AML Mate does not submit it to AUSTRAC. AML Mate does not verify lodgement with AUSTRAC.

Frequently asked questions

Resources

Sources checked 14 October 2026.

• AUSTRAC: suspicious matter reports
• AUSTRAC: tipping off
• AUSTRAC: enhanced customer due diligence
• AML/CTF Act: sections 41, 123, 175 and 235

Related guides

• Threshold Transaction Reports (TTR): Complete Guide
• Suspicious Activity Indicators by Industry
• AUSTRAC Tranche 2: What Australian Businesses Need to Know
• Full AML/CTF Compliance Guide: 7 Steps