Submitting a Suspicious Matter Report (SMR)
What is an SMR?
A Suspicious Matter Report (SMR) is a report you submit to AUSTRAC when you have reasonable grounds to suspect that a client or transaction may be connected to money laundering, terrorism financing, or another serious offence.
Filing an SMR is a legal obligation — not optional. You do not need to be certain that something criminal has occurred. Reasonable grounds to suspect is a lower threshold than certainty.
When you must file
You must file an SMR when you have reasonable grounds to suspect that:
- A client is not who they claim to be
- Information provided by the client may relate to money laundering or terrorism financing
- A transaction has no apparent lawful purpose
- A transaction may be connected to a criminal offence
Deadlines:
- Terrorism financing suspicion: within 24 hours
- Money laundering or other suspicion: within 3 business days
Common real estate red flags that may prompt an SMR include: a cash purchase structured just below $10,000, funds arriving from multiple unrelated accounts, a property purchased sight-unseen at above-market price, or a client who refuses to provide identity documents.
Do not tell the client
It is a criminal offence to tell a client — or anyone else who is not authorised — that an SMR has been filed or will be filed. Keep the matter confidential. Discuss it only with your Compliance Officer and those who need to know internally.
How AML Simple helps
On Professional and Agency plans, AML Simple includes an AI-assisted SMR drafting tool. It guides you through the required fields and helps you write the narrative section describing the basis for your suspicion.
The draft is yours to review, edit, and approve before you submit. You are responsible for the accuracy and completeness of the report.
How to submit
SMRs are submitted via AUSTRAC Online — AUSTRAC’s reporting portal. AML Simple does not submit directly to AUSTRAC on your behalf; it helps you prepare the report.
Log in to AUSTRAC Online at austrac.gov.au to submit.
Record keeping
Keep a copy of every SMR you file. Records must be retained for 7 years from the date of filing. AML Simple stores your SMR drafts with a timestamp; you should also retain a copy of the final submitted version.