What is a TTR?
A Threshold Transaction Report (TTR) is a report you must file with AUSTRAC whenever your business is involved in a transaction of $10,000 or more in physical currency (Australian dollars or foreign currency equivalent). The purpose is to help detect, deter, and disrupt criminal activity including money laundering and terrorism financing.
“Physical currency” means cash — banknotes and coins. It does not include cheques, electronic transfers, or card payments. However, if a customer pays partly in cash and the cash component is $10,000 or more, a TTR is required for the cash portion.
When to report
You must file a TTR whenever you provide a designated service that involves the transfer of physical currency of A$10,000 or more (or foreign currency equivalent). This applies to both receiving and paying out cash.
Deadline: TTRs must be submitted within 10 business days of the transaction.
Key principles
- Each individual cash transaction is a separate designated service — do not combine or aggregate transactions into a single TTR
- If a customer makes two separate $12,000 cash deposits, you file two separate TTRs
- If a customer splits $14,000 into an $8,000 and a $6,000 deposit to two different accounts, neither exceeds the threshold — no TTR is required (but consider whether structuring is occurring)
Exemptions
TTRs are not required when:
- The service is provided at a foreign permanent establishment of your business
- The transaction is between two authorised deposit-taking institutions (ADIs)
- The transaction is between the Reserve Bank of Australia and an Exchange Settlement Account holder
- You only arrange the service (as an AFSL holder) rather than providing it directly
Direct bank deposit exception
If a customer deposits $10,000 or more in cash directly into your bank account, it is the financial institution (not you) that must submit the TTR. However, if you then use those funds to provide a designated service involving cash, you must file a TTR for your transaction.
How to submit
Step 1: Log into AUSTRAC Online
Access AUSTRAC Online at online.austrac.gov.au and navigate to the transaction reporting menu.
Step 2: Select the correct TTR form
AUSTRAC provides four industry-specific TTR forms:
- Financial and bullion
- Gambling
- Investment/superannuation/insurance
- Money services businesses (remittance/currency exchange)
Step 3: Complete the required information
The TTR requires details about:
- The customer — full name, address, date of birth, identity verification documents, account details
- The individual who conducted the transaction — if different from the customer (for example, an employee depositing business takings or a family member acting on behalf of someone)
- The transaction — method, amount, currency, date, and purpose
- The recipient — if the funds are being sent to someone other than the customer
Identity verification must use reliable, independent documentation or electronic sources. The specific information required varies by customer type (individual, company, trust) and the type of designated service.
Step 4: Submit
Three submission methods are available depending on your volume:
- Data entry — enter directly into AUSTRAC Online, suitable for businesses that file a small number of TTRs
- Spreadsheet upload — for multiple transactions
- Data extraction — automated reporting for large businesses with electronic data capture (requires a testing process with AUSTRAC)
When someone else conducts the transaction
If the person making the cash transaction is not the customer — for example, an employee depositing business takings, or a family member acting on behalf of the account holder — you must clearly note this in the TTR and include the details of the individual conducting the transaction.
Check whether the person is actually the customer by looking at: the account holder name, the age and gender of the person versus the account holder, whether the transaction is consistent with the account profile, and any location anomalies (for example, someone depositing at a branch far from the account holder's address).
Non-face-to-face transactions
If the transaction is not conducted face-to-face — such as through a night safe or express deposit box — you do not need to identify the individual who deposited the cash. Instead, provide a statement about the circumstances and include the customer's details.
Multiple transactions and structuring
Each transaction is separate
Each individual cash transaction is a separate designated service. You must file a separate TTR for each transaction of $10,000 or more — do not combine them.
What is structuring?
Structuring is a criminal offence. It occurs when a person deliberately splits a transaction of $10,000 or more into smaller amounts to avoid triggering a TTR. Common examples include:
- A customer depositing $9,500 on Monday and $9,500 on Tuesday instead of $19,000 in one transaction
- A customer making multiple purchases just below $10,000 in cash at a jewellery store over several days
- A customer splitting a large cash payment between different branches or accounts to keep each below the threshold
When to file an SMR for suspected structuring
If you suspect a customer is structuring transactions — that is, the sole or dominant purpose of splitting the transaction is to avoid reporting — you must file a Suspicious Matter Report (SMR). An SMR is required even though the individual transactions are below the $10,000 threshold.
However, not all split transactions are structuring. A customer may have a reasonable explanation — for example, an ATM with a $5,000 deposit limit forcing multiple deposits, or a post office agent with a $7,000 limit. Your transaction monitoring procedures must include triggers for investigating potential structuring and assessing whether a reasonable explanation exists.
Examples
- Customer deposits $4,000 then $7,000 the same day, then $6,500 by cheque and $9,000 the next day — previous income was social security only. SMR required — pattern indicates structuring with no reasonable explanation.
- Customer deposits $15,000 via an ATM with a $5,000 limit across three transactions of $5,000 each. No TTR required — plausible reason (ATM limit), each under threshold.
- Customer deposits $12,000 and $15,000 to two separate accounts. TTR required for both — each exceeds the threshold.
- Customer buys a $10,000 bank cheque and makes a $5,000 deposit totalling $15,000. TTR required for the cheque only — only the cheque purchase exceeds the threshold.
Common mistakes
- Combining transactions: Each $10,000+ cash transaction is a separate TTR — do not aggregate multiple transactions into one report
- Missing the 10-day deadline: Penalties apply for late submission. Set up internal processes to ensure TTRs are filed promptly.
- Not identifying the transacting individual: If someone other than the customer conducts the transaction, their details must be recorded
- Ignoring foreign currency: The $10,000 threshold applies to the Australian dollar equivalent of foreign currency transactions
- Assuming split transactions are fine: If you suspect the purpose of splitting is to avoid reporting, you must file an SMR for structuring
- Incomplete customer information: Identity details must be verified using reliable, independent documentation. Incomplete records can result in compliance action.
Penalties for non-compliance
Failing to submit a TTR within 10 business days can result in penalties of up to 20,000 penalty units for individuals or 100,000 penalty units for body corporates. AUSTRAC takes late and non-submission seriously — these reports are critical to their ability to detect financial crime.
PEP considerations
If the customer involved in a threshold transaction is a high-risk Politically Exposed Person (PEP), you must apply full customer identification checks and Enhanced Due Diligence. This includes all foreign PEPs and any domestic or international organisation PEPs identified as high ML/TF risk. Immediate family members and close associates of PEPs are also considered PEPs.
How AML Mate automates TTR reporting
- Smart pre-fill: Customer details and transaction data are automatically populated from your client records
- Threshold alerts: Automatic notifications when a cash transaction exceeds $10,000
- Structuring detection: Transaction monitoring flags patterns that may indicate structuring
- Deadline tracking: Alerts ensure you file within the 10 business day window
- Step-by-step wizard: Guided TTR form with field validation to catch common errors
- Audit trail: Complete record of all TTRs filed for compliance reviews and AUSTRAC audits
Frequently asked questions
“Does the $10,000 threshold include GST?”
The threshold applies to the total amount of physical currency transferred — this is the gross amount, which would include any GST component.
“What if a customer deposits $10,000 cash into my business bank account?”
If the customer deposits directly into your bank account, the financial institution submits the TTR, not you. However, if you then use those funds to provide a designated service involving a cash transaction of $10,000 or more, you must file a TTR for that transaction.
“Do electronic transfers count?”
No. TTRs are only for physical currency (cash) transactions. Electronic transfers, card payments, cheques, and other non-cash methods do not trigger TTR obligations. However, suspicious electronic transfers may still require an SMR.
“What if the customer refuses to provide ID?”
If a customer refuses to provide identification for a threshold transaction, you should not proceed with the transaction. You should also consider whether the refusal itself is suspicious and warrants an SMR.