If you provide a designated service involving the transfer of $10,000 or more in physical currency, you must submit a TTR to us. The $10,000 threshold applies to foreign currency of the same value. 

This includes receiving or paying in physical currency.

Remittance affiliates 

If you’re a remittance network provider (RNP) you must submit TTRs for threshold transactions carried out by your affiliates.

Submission deadlines

You must submit a TTR to us within 10 business days after the day the transaction takes place. 

When a transaction takes place 

The day a transaction takes place will depend on your products and services. 

Example: Real estate transaction, deposit and settlement

Customer A is buying a property through a real estate agent. On day one, Customer A gives the agent $21,250 as a physical currency deposit. 

Customer A signs the sale contract a week later, with settlement occurring 6 weeks later. Customer A paid the settlement balance by electronic transfer into the real estate agent’s trust account. 

In this example, a threshold transaction took place on day one, when Customer A paid the agent in physical currency. 

The agent must file a TTR within 10 business days after this date. As Customer A paid the settlement amount by electronic transfer, this second payment doesn’t need another TTR.

What to include

Your TTR must include details of:

• the date you report the TTR
• your business or organisation
• the individual completing the report. If the report is system generated, include details of an individual accountable for completing and submitting the TTR,
• the customer involved in the transaction
• any other parties involved in the transaction. For example, a counterparty, an agent, trust or beneficial owners.

If someone is acting on behalf of a customer, you must also include: 

• a description of their relationship. For example, employee and employer
• a description of authority to act. For example, the employee has authority to transact on the employer’s transaction account up to $200,000
• reportable details about any individual or non-individual involved.

Your TTR must have transaction details, including:

• when and where it took place
• the role of any individual or non-individual involved, if known
• the purpose of the transaction, if known
• its Australian dollar value
• if foreign currency is involved, the amount and type of currency
• designated services provided.

If the transaction involves an account, your TTR must include details of:

• the type of account such as loan, credit card, savings
• any unique identifiers such as BSB and account numbers, or proxies such as payID or card numbers
• the date the account was opened
• any individual or non-individual involved.

Accounts aren’t limited to authorised deposit-taking institutions (ADIs) and may include any designated service. For example:

• online betting accounts
• precious metals and stones dealers, both wholesale and trade accounts
• virtual asset accounts or wallets.

If used in the transaction, your TTR must also include details of:

• the transaction products or ‘instruments’ used. For example, gaming chips, shares, cheques, store value cards, precious metals
• any property transfer, such as real estate or bullion.

If a TTR involves virtual assets, you must include details of:

• the virtual asset type
• any virtual asset wallet addresses involved, including destination tags and memo details
• the value in Australian dollars and exchange rate
• any individual or non-individuals involved. 

If the TTR relates to someone else providing a designated service, you must include the:

• full name of the individual or non-individual providing the service
• address where they provide that service
• kind of service they provide.

If the TTR relates to providing a designated service online, you must include the following details, if known:

• the full name and any usernames of any individual or non-individuals involved
• network identifiers used. For example, Internet Protocol (IP) address
• identifier numbers for devices used. For example, International Mobile Equipment Identity (IMEI)
• the date and time of the online activity (if different from when the transaction took place).

A comprehensive list of details required within your TTR is available. 

Learn more at Division 2 of Part 9 of the Anti-Money Laundering and Counter-Terrorism Funding Rules (the Rules). 

The information above differs from what you currently need to provide in a TTR and you’ll be required to provide it using the new form (this will become available before the laws start). 

When current reporting entities need to change to the new TTR form 

You’ll need to continue using the current TTR form until 1 July 2026.

From 1 July 2026 to 30 March 2029, current reporting entities will have the choice to submit a TTR using:

• the current form where you need to give the information you were required to provide before 1 July 2026
• the new form which requires you to provide the new information at division 2 of part 9 of the Rules.

This only applies if you were on the Reporting Entities Roll on 30 March 2026. 

If you weren’t on the Reporting Entities Roll on 30 March 2026, you’ll need to use the new TTR form from 1 July 2026.

Multiple physical currency transactions

If a customer makes multiple physical currency transactions, you must treat each as a separate transaction. A transaction is a single payment, even if it’s for multiple services. 

You don’t need to combine the value of each separate transaction even if they occurred quickly or at another location. 

However, you should be aware of customers who may be structuring their transactions to avoid reporting and consider whether a suspicious matter report (SMR) may be required. 

You must submit a TTR for each physical currency transaction of $10,000 or more.

Example: TTR not required

Customer B wants to buy a $20,000 diamond bracelet from a local jeweller. Customer B tells the jeweller they’re unable to pay in full and will pay instalments for a month. 

Customer B pays $2,000 in physical currency instalments to complete the purchase.

While the total is more than $10,000, the customer pays this through separate transactions. A TTR isn’t required. 

However, the jeweller should consider if Customer B is paying by instalments to avoid TTR. They should submit a suspicious matter report (SMR) if they suspect this.

Example: TTR required

Customer B wants to pay off their car loan at their local bank branch. Customer B wants to pay in physical currency for the $9,800 balance. 

The bank tells Customer B about the early repayment fee of 2.5% on the remaining loan amount. This brings the amount payable to $10,045. Customer B pays the total transaction amount of $10,045 in physical currency. 

The bank must submit a TTR for this transaction.

Example: TTR required

Customer M goes to a remittance service provider with $12,000 in physical currency to send to their family overseas. 

Customer M sends $2,000 to their family in one transaction. In a separate transaction, they send the remaining $10,000.

The remittance service provider has provided 2 separate transactions to Customer M.

The provider doesn’t need to report the first transfer of $2,000. However, the provider must submit a TTR for the second transaction. This is because it meets the reporting threshold of $10,000 or more.

Example: TTR not required

Customer S goes to a currency exchange business to buy foreign currency before an overseas holiday. Customer S uses Australian physical currency to buy $7,000 of euros and $7,000 of pounds sterling.

As these are separate transactions, there’s no need to submit a TTR, even if they happened at the same time.

Structuring

Structuring happens when someone divides large physical currency transactions into smaller ones to avoid threshold reporting. It’s a common money laundering technique. Structuring to avoid reporting is a criminal offence.

What you must do to address structuring

You must monitor your customers for any unusual transactions and behaviour. If you have reasonable grounds to suspect a customer is structuring transactions to avoid TTR reporting, you must submit an SMR.

If you keep providing a designated service to the customer, you must conduct enhanced customer due diligence (CDD). This involves gathering information to understand if it was to avoid reporting or for legitimate reasons.

Learn more about: 

• ongoing CDD
• enhanced CDD
• SMRs.  

Examples of TTRs and SMRs

Below are examples where an SMR is needed because there are reasonable grounds to suspect a customer is structuring their transactions to avoid TTR reporting. 

See more examples of structuring. 

Multiple bank deposits – automated monitoring – SMR required

Customer C visits their bank and deposits $4,000 in physical currency. Later that day, they return to deposit another $7,000 in physical currency. The next day, Customer C returns to buy a bank cheque with $6,500 in physical currency and deposits $9,000 in physical currency. 

The banks’ transaction monitoring system triggers an alert because the transactions: 

• occurred over a pre-set number of days
• are under the threshold transaction limit. 

An investigation shows the customer receives Centrelink payments. The transaction monitoring team decide the recent behaviour is inconsistent with their profile. 

The bank forms a suspicion on reasonable grounds that Customer C is trying to avoid a TTR. 

The bank then submits a SMR and conducts enhanced CDD.

Real estate deposit – manual monitoring – SMR required

Customer C makes an offer to buy an apartment, which the vendor accepts. Customer C agrees to pay a 10% deposit of $50,000.

The real estate agency’s AML/CTF policy includes a simple manual transaction monitoring system. The employee flags threshold transactions and structuring activity. 

Customer C says they received money from a relative and want to pay a physical currency deposit. Customer C asks if they can pay the deposit in: 

• 5 separate transactions of $9,000
• 1 transaction of $5,000. 

The agent thinks this could be suspicious. They ask Customer C why they need to pay this way. Customer C becomes irritated and brushes off the question without providing a legitimate reason.

The agent decides this is reasonable grounds to suspect structuring and submits an SMR. 

Exemptions

You don’t have to submit a TTR if you provide a designated service involving a threshold transaction in these situations:

• the service is provided at or through your permanent establishment in a foreign country, except if you’re a RNP. You may still need to report under the laws of the foreign country.
• you have an Australian financial services licence and are arranging for a person to receive a designated service
• you’re an ADI providing services to another ADI
• you and your customer are both using exchange settlement accounts (ESA).

Related pages

• Reporting landing page
• Suspicious matter reports