Reporting transactions of $10,000 and over: Threshold transaction reports (TTRs)

If you provide a designated service that involves a threshold transaction, you must submit a TTR unless you have an exemption.

If you are an affiliate of a remittance network provider (RNP) and the threshold transaction was made on your RNP’s network, they must submit the TTR for you.

You should submit TTRs through AUSTRAC Online.

There are four different TTR report forms and detailed instructions on how to fill them in are available in AUSTRAC Online for different industry sectors:

1. financial and bullion services
2. gambling services
3. investment/superannuation/insurance
4. money services businesses (remittance service providers and currency exchange providers).

If you don’t fit into one of these groups, use the financial and bullion services form.

You can submit reports online through:

• Data entry – TTRs can be completed and submitted manually. This option is suitable if you don’t submit many reports.
• Spreadsheet – you can enter TTR data into a spreadsheet available through AUSTRAC Online.
• Extraction – you can use a computer program to extract relevant transaction information from your database, collate it into a single file and send it to us via AUSTRAC Online. This option is suitable if you’re a large business that captures and stores transaction data electronically. Instructions on this method are available in AUSTRAC Online.

After you submit a TTR

A completed report is confidential. The only people who are allowed to know about the report and its contents are people within your organisation who have reporting responsibility.

Officials from AUSTRAC or one of our partner agencies may ask you in writing to provide more information about a TTR. This may be information you have about a customer or a particular transaction, such as account information or customer details, that could help us in an investigation. You are legally required to provide this information if asked.

TTRs must include details about:

• the customer
• the individual who conducted the transaction (if they weren’t the customer)
• the transaction, including the amount of cash, digital currency and any other currency
• the recipient of the money (if they weren’t the customer)
• your business or organisation.

The information you must include in a TTR depends on:

• the type of customer (for example, different information is required for companies compared to trusts)
• whether the individual making the transaction was not the customer (you will need additional information if this is the case)
• the type of designated service you provided to the customer
• your business activities.

There is more information below about how to make TTRs in special circumstances.

Full instructions for what must be included and how to fill in the different TTR forms are in AUSTRAC Online.

The customer is not necessarily the individual making the threshold transaction. If this is the case your TTR must state this, and include details about the individual making the transaction. This includes individuals who are:

• an employee 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 which is not the customer
• conducting the transaction on behalf of a family member or friend.

Carefully check whether the individual conducting a threshold transaction is the customer of the designated service. For example, you could check to see if an individual making a deposit into an account is the account holder.

It’s reasonable for you to accept that the individual is the customer unless you have good reason to believe otherwise. This might be because, for example:

• 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 supply the details accordingly.

You can use information you have previously collected from the individual to complete the TTR.

Identifying a customer who is not present

When the individual making the threshold transaction is not the customer of the designated service, the customer is often not present when the transaction is made. In some cases, you won’t know the customer because you haven’t provided a designated service to them before and therefore haven’t identified them. In these cases, you may consider collecting identifying information about the customer from the individual who wants to make the transaction and verifying this information before you provide the service.

If you can’t collect or verify the information, you may decide not to provide the service.

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.

When the customer making the transaction 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. Note: immediate family members or close associates of PEPs are also considered to be PEPs.

Multiple signatories on an account

If there are multiple signatories to an account, you are only required to report the details of the individual signatory who authorised the threshold transaction. This is because some accounts (such as corporate accounts) may have many signatories and it can be impractical for a reporting entity to collect the details of all the individuals. However, AUSTRAC can ask you to give us information about any other signatory to the 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.

If you provide multiple services to a customer that add up to A$10,000 or more (or the foreign currency equivalent) when combined, you must decide whether to treat these services as a single reportable transaction or separate transactions. Generally, if the services are similar transactions that happen in quick succession they should be considered a single transaction. This might include cash withdrawals or account deposits.

Example of reporting multiple cash transactions in a single TTR

Mr Grey visits Elm Bank and makes two cash deposits of A$7000 each into the same account because he wants two separate line items in his bank statement for bookkeeping purposes.

Because Elm Bank provided one designated service (transferring physical currency of A$14,000) to one customer, Elm Bank must report the transaction to AUSTRAC as a single TTR with a value of A$14,000.

Example of reporting multiple cash transactions in a separate TTR

Ms Indigo visits her financial institution and hands over A$25,000 in cash. She asks to make a deposit of A$13,000 into her bank account, and buys A$12,000 worth of foreign currency.

Because Ms Indigo received two different designated services, two transactions occurred. Each transaction involved transferring A$10,000 or more, so the financial institution must report both transactions to AUSTRAC in two separate TTRs.

Structuring is a money laundering technique which involves transactions being deliberately split into smaller amounts to avoid threshold transaction reporting. Structuring is an offence that can lead to a five-year jail term or a fine of up to 300 penalty units for individuals and up to 1500 penalty units for corporations. Find out more about enforcement and penalties.

If you have ‘reasonable grounds’ to suspect that a customer is structuring or attempting to structure their transactions so they will not be reported, you must submit a suspicious matter report (SMR) to AUSTRAC. ‘Reasonable grounds’ means that after considering all the information and circumstances available, a reasonable person would conclude an SMR should be submitted.

Example of structuring to avoid TTRs

Ms Cerise visits Cedar Bank and deposits A$4000 cash into her account. The next day, she returns to Cedar Bank and purchases a bank cheque with A$6500 cash and deposits another A$9000 cash into her account. After reviewing Ms Cerise’s previous transactions and her known sources of income (she is unemployed), Cedar Bank suspects she is structuring her transactions to avoid the TTR requirements. To comply with the law, Cedar Bank submits an SMR to AUSTRAC.

You don’t have to submit a TTR if:

• the designated services are provided at or through your permanent establishment in a foreign country
• you hold an Australian Financial Services Licence (AFSL) and only arrange for a person to receive a designated service rather than providing it yourself.

TTR obligations also don’t apply when the designated service involving a threshold transaction is:

• provided by an authorised deposit-taking institution (ADI) to a customer that is also an ADI
• provided by the Reserve Bank of Australia to a customer that holds an exchange settlement account (ESA) (that is, an account held at the Reserve Bank for settlement of obligations between ESA holders)
• provided by an ESA holder to a customer that holds an exchange settlement account.

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