How to submit a threshold transaction report (TTR)
You must submit a threshold transaction report (TTR) within 10 business days of the transaction taking place.
To submit a TTR:
- log in to AUSTRAC Online
- navigate to the transaction reporting menu
- choose the appropriate TTR form.
There are four different TTR report forms available in AUSTRAC Online for different industries:
- financial and bullion
- money services businesses (remittance service providers and currency exchange providers).
There are detailed instructions on how to complete the TTR forms in AUSTRAC Online.
The TTR report forms you will have access to in AUSTRAC Online is based on the designated service types you select when you enrol or register with AUSTRAC. If you don’t have access to the correct TTR form, please contact the AUSTRAC Contact Centre.
You can submit TTRs through:
- Data entry – by entering the transaction information directly into the report form in AUSTRAC Online. This option is suitable if you don’t submit many reports.
- Spreadsheet – by entering the transaction information into a spreadsheet available through AUSTRAC Online. This option is suitable if you have multiple transactions to report.
- Extraction – by using a computer program to extract relevant transaction information from your database, collating it into a single file and uploading it to AUSTRAC Online. This option best suits large businesses that capture and store transaction data electronically. To request this function in AUSTRAC Online, the file must first go through a testing process which can be arranged through the AUSTRAC Contact Centre.
Information your TTRs must include
Your TTRs must include details about:
- the customer, which includes the account holder and any signatory or signatories to the account conducting the transaction (refer to Rule 19.4)
- the individual who conducted the transaction (if they weren’t the customer)
- the transaction, including the method of conducting the transaction and the amount of cash, digital currency and any other currency
- the recipient of the money (if they weren’t the customer)
- the reliable and independent documentation and/or electronic data source(s) used to verify the identity of the customer
- your business or organisation.
Other information you must include in a TTR will depend on:
- the customer type (for example, different information is required for companies compared to trusts)
- the individual making the transaction – if the person making the transaction was not the customer, you will need to include additional information
- the type of designated service you provided to the customer
- your business activities.
Special circumstances affecting the information required in a TTR
There are special circumstances that may affect the level of detail you are required to provide in a TTR. We have outlined some scenarios below to give you further clarity on the information you will need to include in your TTR.
When the person making the transaction is not the customer
The customer may not be the individual making the transaction. For example, individuals who are:
- employees acting on behalf of the customer (such as depositing business takings)
- conducting the transaction on behalf of an organisation such as a trust or association that is not the customer
- conducting the transaction on behalf of a family member or friend.
When the individual making the transaction is not the customer your TTR must state this, and include details about the individual making the transaction.
You must carefully check whether the individual conducting a threshold transaction is the customer of the designated service. To do this, you could check to see if an individual making a deposit into an account is the account holder. You may be able to determine that the individual is not the customer when:
- the individual tells you directly they aren’t the customer
- the account is in the name of a business or organisation
- you notice an obvious difference in age or gender between the individual making the transaction and the personal details of the account holder
- the type or size of transaction isn’t consistent with the customer’s previous financial activity or their financial profile
- the transaction happens at a location not normally associated with the customer, such as interstate.
If you don’t know whether the customer or someone acting on their behalf made a transaction, you must fill in the TTR form as if the individual was the customer and provide the details accordingly.
You can use information you have previously collected from the individual to complete the TTR.
When you don’t have to provide an individual’s details
You don’t have to include the details of the individual who made the transaction in a TTR if:
- the transaction wasn’t made face-to-face (for example, a deposit made through a night safe or express deposit box)
- the transaction involved an individual from a cash courier service.
Instead you must give AUSTRAC a statement about the circumstances of the threshold transaction, as well as the customer details.
The customer is a politically exposed person (PEP)
If your customer is a high-risk politically exposed person (PEP), you must:
- apply all customer identification checks if you have not previously identified the customer
- undertake all enhanced customer due diligence checks if you have not previously identified the customer.
Enhanced customer due diligence procedures include considering whether or not you should process particular transactions, and whether existing customer identification information you have on record should be updated or re-verified.
High-risk PEPs include all foreign PEPs, and those domestic or international organisation PEPs you identify as a high risk of money laundering or terrorism financing. Immediate family members or close associates of PEPs are also considered to be PEPs.
TTR obligations when a customer deposits A$10,000 or more directly into your bank account
If a customer deposits physical currency of A$10,000 or more (or the foreign currency equivalent) directly into your bank account (rather than paying you in cash), you do not have to submit a TTR.
It is the responsibility of the financial institution that accepts the cash to report it to AUSTRAC. This is the case even if you use those funds to provide a designated service.
Example of a direct deposit into a reporting entity’s bank account
Mr Green deposits A$20,000 into his stockbroker’s bank account. The stockbroker, Ms Crimson, has an account with Elm Bank. Ms Crimson uses the money to buy securities on Mr Green’s behalf without physically handling any currency. Elm Bank must submit a TTR to AUSTRAC because the initial deposit involved a designated service above the threshold.
Because Ms Crimson didn’t handle any physical currency when buying the securities, she doesn’t have to report the second transaction to AUSTRAC or submit a TTR.
If Ms Crimson had paid for securities on Mr Green’s behalf with cash, she would have been required to submit a TTR.
What happens after you submit a TTR
From time to time, AUSTRAC or one of our specific government agency partners (as listed below) may issue you with a formal written notice requesting further information about a TTR you have submitted. This might include asking you for further details about the customer and/or other transactions conducted in relation to the same account. You are legally required to provide this information if you receive such a written notice.
You must not disclose to anyone except AUSTRAC, the partner agency that issued the written notice, or any other partner agency that has previously issued you a formal written notice in relation to the same TTR, that you have received the written notice or have provided information in response to the written notice.
You must also not disclose to anyone, information from which it could be reasonably inferred that you have received the written notice or responded to the written notice.
In addition to AUSTRAC, the partner agencies that may issue you a written notice seeking further information about a TTR you have submitted are the Australian Federal Police (AFP), the Australian Criminal Intelligence Commission (ACIC), the Australian Taxation Office (ATO), the Australian Border Force (ABF), and Australian Commission for Law Enforcement Integrity (ACLEI).
Example of what happens if additional information is requested
You submit a TTR in relation to a threshold transaction conducted by Customer A. The AFP issues you a written notice asking for more information about the threshold transaction. Two weeks later, the ACIC also issues you with a separate written notice asking for more information about Customer A and all other transactions conducted on the account to which the TTR relates. You respond to both written notices from the AFP and the ACIC.
You must not disclose to anyone except AUSTRAC, the AFP or the ACIC about the two written notices or your responses.
Penalties for not submitting a TTR
If you fail to submit a TTR within 10 days of the transaction taking place or not at all, you can be fined up to up to 20,000 penalty units, or up to 100,000 penalty units if you are a body corporate. Find out more about the 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.