Submitting your SMR

You can submit an SMR through your AUSTRAC Online account.

  1. log in to AUSTRAC Online 
  2. navigate to the transaction reporting menu
  3. select the + sign next to the transaction reporting menu, then select ‘create amend reports’ and ‘SMR
  4. complete and submit your report

There are detailed instructions on how to fill in an SMR form in AUSTRAC Online.

What makes a good SMR?

A good SMR explains clearly and concisely why you think the customer’s behaviour is suspicious. Use your own words and include as many details as possible. For example, if you can’t identify the customer, you might include details about how old they looked, what they were wearing, the colour of their hair etc.

Your grounds for suspicion, including the reasons why you’re submitting an SMR, should follow plain English principles with information structured in a clear and logical way.

For more information about submitting effective SMRs, refer to:

What your SMR must include

An SMR must include details about your business or organisation and everything you know about:

  • the suspicious matter
  • the person/organisation it relates to
  • any transactions involved.

For individuals, you must include, if known:

  • their full name, address and telephone number
  • their date of birth
  • country of citizenship
  • occupation, type of business activity and ABN
  • email address
  • any other name they use
  • a description of the documents or electronic data you used to verify their identity.

If you don’t know someone’s identity, the SMR should instead include:

  • a description of the person
  • whether you have any video footage or photographs of them
  • their address and email address, if known.

Reporting an SMR where your customer may be the victim of a crime

If your customer is the potential victim of a crime, rather than a suspected offender, complete the fields as described below when reporting this type of SMR.

Grounds for suspicion (SDE: ‘Part B’ / XML: ‘groundsForSuspicion’)

  • Include the circumstances that led you to form a suspicion and any relevant information, including from other parts of the SMR.

Details of the person/organisation to which the suspicious matter relates (SDE: ‘Part C’ / XML: ‘suspPerson’)

  • If your customer is the potential victim of a crime rather than the suspected offender, they should not be reported here.
  • This section must include the person or organisation to which the suspicious matter relates, i.e. the suspicious person. If you do not know the identity of the suspicious person, you can include ‘unknown’. Other sections should still be completed with any information you do know about the suspicious person.

Details of any other party to which the suspicious matter relates (SDE: ‘Part D’ / XML: ‘otherPerson’)

  • In this section you must include information about any other party (individual or organisation) related to the suspicious matter. Include details of the customer who may be the victim of a crime.
  • You can also include multiple parties, joint or authorised signatories to an account.

Suspicious person whose identify could not be established (SDE: ‘Part E’ / XML: ‘unidentPerson’)

  • If you don’t know the identity, include any descriptions or other supporting information here, such as observations about their manner of speaking or walking etc.

Specific details such as names, emails, phone numbers and account numbers, etc. should not be reported here. These must be reported in Part C / suspPerson.

Deadlines for submitting an SMR

The SMR reporting deadlines start once the appropriate person in your business or organisation has formed a suspicion, which may be at any time in your business relationship.

A suspicion is only ‘formed’ after the appropriate person in your business or organisation has conducted enhanced due diligence checks and determined that there are reasonable grounds for suspicion.

Remember, your SMR must be submitted within:

  • 24 hours if the suspicion relates to terrorism financing
  • or within 3 business days if the suspicion relates to money laundering or any other offence.

What happens after you submit an SMR?

To help with our investigations, we may ask you for more information about an SMR you’ve submitted. Our partner agencies also have the right to ask for further information in some circumstances. We will issue a written notice asking for this information. This might include asking you for further details about the customer or a specific transaction or account. If you don’t provide the information when asked you can be fined.

The SMR you submit is not admissible as evidence in court, but it can be used in criminal proceedings for some AML/CTF Act offences, such as if you tip off a customer or provide false or misleading information.

Penalties for not submitting an SMR

If you submit an SMR late – or don’t submit one when you should – you can be fined up to 20,000 penalty units in the Federal Court of Australia, or 100,000 penalty units if you’re a body corporate. Find out more about consequences of not complying.

The content on this website is general and is not legal advice. Before you make a decision or take a particular action based on the content on this website, you should check its accuracy, completeness, currency and relevance for your purposes. You may wish to seek independent professional advice.

Last updated: 14 Dec 2022
Page ID: 638

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