Reporting multiple cash transactions
AUSTRAC has updated its guidance position on the reporting of threshold transaction reports (TTRs) when a customer conducts multiple cash transactions.
This follows stakeholder consultation with the release of draft guidance on 11 November 2021.
AUSTRAC is providing a 12-month transition period from 1 July 2022 to enable reporting entities to update their systems, procedures and staff training to fully comply with this outcome.
For more information, read AUSTRAC’s letter of intent outlining our expectations on implementing the revised TTR requirements.
When your customer makes multiple cash transactions, each individual transaction is considered to be a separate and distinct designated service. You don’t need to combine or aggregate the transactions and submit a TTR, even if the transactions occurred in quick succession. You must submit a TTR to AUSTRAC for each individual cash transaction of A$10,000 or more.
If you suspect your customer is structuring their transactions to avoid the TTR reporting threshold, or is transacting with proceeds of crime, you must submit a suspicious matter report (SMR) to AUSTRAC.
Customers may deliberately split a larger cash transaction into several smaller transactions to try to avoid a TTR being submitted. This is called structuring, a common money laundering technique used to launder illicit funds. Structuring transactions to avoid reporting is a criminal offence.
You must consider whether your customer has a reasonable explanation for conducting multiple transactions, or whether this activity is suspicious. If you reasonably suspect that transactions have been structured to try and prevent them from being reported in a TTR, you must submit an SMR to AUSTRAC.
Your transaction monitoring program must be able to detect possible structuring of cash transactions and include triggers for further investigation and reporting to AUSTRAC if required.
These examples illustrate when a TTR is required. In each of the examples, you must also consider if there are reasonable grounds for suspicion based on the particular circumstances. If you have reasonable grounds to believe the transactions could be linked to criminal activity, or that a customer is attempting to structure their transactions to avoid being reported, you must submit an SMR to AUSTRAC.
See Reporting structuring for more information and examples of structuring transactions.
Example 1: Splitting a transaction into two accounts – TTR not required
Jane holds several accounts with Bank A. She visits the bank with $14,000 in cash and asks to deposit $8,000 into one account and $6,000 into another account.
Each deposit is considered to be a separate designated service. Bank A does not need to submit a TTR for either deposit as neither of the deposits meet the $10,000 threshold.
Example 2: Splitting a transaction into two accounts – TTR required
Brian holds several accounts with Bank B. He visits the bank with $14,000 in cash and asks to deposit $11,000 into one account and $3,000 into another account.
Bank B has provided two separate designated services to Brian. As the first transaction exceeds the $10,000 threshold, Bank B has an obligation to submit a TTR to AUSTRAC for that transaction.
The obligation to provide a TTR does not apply to the second transaction of $3,000, as this transaction does not meet the $10,000 threshold.
Example 3: Splitting transaction into two accounts – TTR required
Wei holds two accounts with Bank C. He visits the bank with $27,000 in cash and deposits $15,000 into his first account and $12,000 into his second account.
Bank C has provided two separate designated services to the customer. Both transaction amounts exceed the $10,000 threshold. Bank C has an obligation to submit two TTRs to AUSTRAC – one for the $15,000 transaction and one for the $12,000 transaction.
Example 4: Transaction limits – splitting transactions into the same account
On Monday, Pam visits a branch of Bank D to deposit $12,000 in cash into an account she holds. Pam says she operates a small business and would like to split the deposit into three transactions to align with her business turnover for Friday, Saturday and Sunday. Pam explains that this will make the reconciliation process with her accounting software easier and more accurate.
Pam deposits the following amounts of cash into her account:
- 1.00pm Friday’s turnover - $4,500
- 1.04pm Saturday’s turnover - $4,500
- 1.09pm Sunday’s turnover - $3,000
Although these transactions were conducted at close intervals, there is no obligation to submit a TTR because each deposit represents a separate designated service and none of the deposits involve a threshold transaction. Further, an SMR is likely not required if Pam’s explanation for the split transactions is reasonable and plausible based on Bank D’s knowledge and understanding of Pam’s customer profile and business activities.
Example 5: Transaction limits – splitting transactions into the same account through an ATM
Scarlett attends an ATM of Bank E to deposit $15,000 in cash into an account she holds with the bank. Bank E has a cash deposit limit on its ATMs of $5,000.
Scarlett deposits the following amounts of cash into her account:
- 1.00pm $5,000
- 1.05pm $5,000
- 1.10pm $5,000
Although these transactions were conducted at close intervals, there is no obligation to submit a TTR because each deposit represents a separate designated service and none of the deposits involve a threshold transaction. The requirement to report an SMR may also not arise given there is a plausible reason for the split transactions.
Example 6: Transaction limits – deposit into a single account via an intelligent ATM when an error occurs
Alexandra attends an intelligent ATM operated by Bank E and deposits $30,000 of cash into her account. Unbeknown to Alexandra, the deposit jams and $17,000 is credited to her account, while the remaining $13,000 is retained by the ATM in a drawer for rejected funds. This results in Bank E initially reporting a TTR for $17,000 to AUSTRAC.
Three days later Alexandra identifies that the full value of the deposit is not in her account and she lodges a transaction dispute. Bank E subsequently investigates and verifies the amount disputed by Alexandra. Bank E then credits the missing $13,000 to her account.
In this example, Bank E has commenced to provide a designated service to Alexandra by enabling her deposit of $30,000 into the intelligent ATM to crediting the funds to her account. Bank E is allowing Alexandra to ‘conduct a transaction in relation to her account’ in accordance with item 3, table 1 of section 6 of the AML/CTF Act.
Bank E has an obligation to submit a TTR for Alexandra’s $30,000 deposit into an ATM for the purpose of crediting the funds to her account. Once the dispute involving the missing funds has been resolved with Alexandra, Bank E must amend the TTR it submitted to AUSTRAC relating to the $17,000 that was initially credited to Alexandra’s account so that it includes the missing $13,000 that was later credited to her account. These missing funds formed part of the initial transaction and so must be reported in the TTR. The TTR must reflect the sum of $30,000 deposited by Alexandra at the intelligent ATM.
Subsection 43(2) of the AML/CTF Act requires a reporting entity to submit a TTR within 10 business days of the transaction taking place. It is important to note that, in this example, the timeframe for submitting the TTR commences on the day of Alexandra’s deposit as this is the date on which the transaction took place. Depending on how quickly a disputed transaction is brought to the attention of, and resolved by, the reporting entity, it may not always be possible for the reporting entity to amend the TTR within the 10 business day timeframe. In this situation, AUSTRAC’s expectation is that, at the very least, the initial (erroneous) TTR should have been submitted within the 10 business day timeframe and for the subsequent amendment to be made as soon as the disputed transaction has been resolved.
As a result of this incident, Bank E reviews its processes and procedures concerning the operation of intelligent ATMs. The purpose of the review is to address situations where funds may become jammed and also to ensure that Bank E can correctly and effectively comply with the 10 business day timeframe for reporting a TTR to AUSTRAC.
Example 7: Transaction limits – splitting transactions into the same account
Leo visits a post office to deposit $11,000 in cash into his account with Bank F. The post office acts as an agent for Bank F and applies a cash deposit limit of $7,000.
Due to the limit, Leo deposits the following amounts of cash into his account:
- 1.00pm $7,000
- 1.05pm $4,000
Although these transactions were conducted at close intervals, there is no obligation to submit a TTR because each deposit represents a separate designated service and neither of the deposits involve a threshold transaction. Similar to examples 4 and 5, this scenario may or may not give rise to SMR obligation if there is a plausible explanation and the circumstances do not otherwise raise suspicion.
Example 8: Purchase of a bank cheque
Vijay visits a branch of Bank G to purchase a bank cheque for $10,000 and make a deposit of $5,000 into an account he holds with the bank. Vijay also pays a $10 fee for the bank cheque.
To complete the deposit and purchase of the cheque, Vijay hands over a total of $15,010 in cash to the teller.
Two designated services are provided by Bank G – the $5,000 deposit and the purchase of the $10,000 cheque. Bank G has an obligation to submit a TTR for the purchase of the $10,000 cheque.
Under Chapter 19 of the AML/CTF Rules the bank is required to include additional information in the TTR about the bank cheque including the physical currency used to purchase it.
The fee for the cheque is not included as part of the designated service.
Example 9: Purchase of two or more foreign currencies
Sophia attends a currency exchange business to purchase foreign currency ahead of an overseas holiday. Sophia uses Australian cash to make the following foreign exchange transactions:
- Purchase A$7,000 worth of Euros
- Purchase A$7,000 worth of Pounds Sterling
There is no obligation to submit a TTR because each currency exchange is a separate designated service, even though they were conducted within a short timeframe. Neither of the currency exchange transactions involve a threshold transaction.
Example 10: Purchase of gaming chips – TTR not required
Allan attends Casino H and exchanges $7,000 in cash for gaming chips at the casino cage. He then goes to a blackjack table and purchases another $5,000 in gaming chips using cash.
There is no obligation to submit a TTR because each purchase of the gaming chips is a separate designated service, despite the short timeframe between transactions. Neither of the transactions involve a threshold transaction. However, if Allan’s behaviour raises suspicion of possible structuring because there does not appear to be a reasonable and plausible explanation for his behaviour, then a SMR must be submitted.
Example 11: Sending money overseas – TTR required
Margaret attends a remittance service provider with $12,000 cash to send money to her family and contribute to the development of a community centre in a foreign country. Margaret sends $2,000 to her family in one transaction. In a separate transaction she sends the remaining $10,000 which was collected from her extended family and friends for the development of the community centre.
The remittance service provider has provided two designated services to Margaret.
No TTR is required for the first transaction of $2,000, as this transaction does not meet the $10,000 threshold. There is an obligation to submit a TTR for the second transaction because it meets the threshold of $10,000 or more in physical currency.
Example 12: Wagering on a horse race
Following a tip from a friend, Robert visits his local wagering outlet to place a single bet on a horse called Lucky Ned, who is scheduled to race at the Metropolitan Racecourse at 2:30 PM that same day.
The bet is for an outright win and he hands over $12,000 in cash for the wager.
The staff require Robert to provide identification documentation because the wager exceeds the $10,000 threshold for identification and verification.
Having correctly identified and verified Robert, the wagering outlet accepts Robert’s bet. As the transaction exceeds the TTR threshold of $10,000 in physical currency, the wagering outlet must submit a TTR to AUSTRAC.
Example 13: Placing multiple wagers on a greyhound race
Raelene attends a greyhound racing meet and undertakes three separate ‘each way’ bets. Each bet is for a sum of $4,000 on Lucky Charm in the Rural City Greyhound Racing Cup, the main event on the program. Her total outlay is $12,000 in cash.
There is no obligation to submit a TTR because each bet (totaling $4,000 each) represents a separate designated service and is below the $10,000 threshold.
Example 14: Placing multiple wagers on various races
Edward is a horse racing enthusiast and punter and likes to get to his local wagering outlet relatively early so he can place his bets for the day.
On arrival at his wagering outlet, he places: two $4,000 ‘each way’ bets on Chance Encounter in Race 2 at Capital City Racecourse; a $4,000 bet to win on Sweet Potato on Race 4 at Interstate Racecourse and a $2,000 bet on Blue Boots in Race 5 at Capital City. The total amount of Edward’s bets is $14,000 and he passes over this amount in cash.
There is no obligation to submit a TTR because each bet represents a separate designated service and the amount of each bet is below the $10,000 threshold.
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