AML/CTF Rules 2025: Reporting for accounting

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Understanding AML/CTF Rules 2025 Part 9: Reporting, and what it means for the accounting sector

From 1 July 2026, Australian accounting practices will need to lodge reports with AUSTRAC in certain situations. These reports are a core part of the AML/CTF framework as they help regulators spot money laundering and terrorism financing risks at an aggregate level across accounting services.

For accounting firms, the three most common reports will be:

• Suspicious Matter Reports (SMRs) – when something about a customer or matter doesn’t feel right.
• Threshold Transaction Reports (TTRs) – whenever someone pays $10,000 or more in cash or equivalents, even if nothing looks suspicious.
• Annual AML/CTF compliance report - shows how your firm is meeting obligations.

Suspicious Matter Reports (SMRs)

When to lodge

You must lodge an SMR if you suspect something about a client or matter may be linked to:

• Money laundering or terrorism financing
• Sanctions breaches
• Fraud, bribery, corruption, or other serious offences
• Identity concerns (customer or agent not who they say they are)
• Unusual transactions (no clear business/legal purpose, unusually complex, or inconsistent with the client’s profile)

The suspicion can arise:

• When you’re asked to provide a service,
• While you’re providing it, or
• After the service is complete.

What to include

An SMR requires:

• Your firm's details: Name, AUSTRAC ID, submission date.
• Staff details: Name, role, contact info of person lodging the report + another contact who can explain the suspicion.
• Customer details:
  • individuals (full name, DOB, citizenship, addresses, occupation, ID docs)
  • non-individuals (company/trust names, registration details, directors, beneficial owners).
• Why you’re suspicious: E.g. funds don’t match profile, beneficial owner hidden, unusual payment pattern.
• Transaction details: E.g. company formation, tax advisory, offshore structure, accounts involved
• Links to other parties: Anyone acting on behalf of the customer, related businesses, signatories, intermediaries.
• Supporting evidence: Documents, images, online records, or anything that supports your suspicion.

Examples

• A long-standing tax client suddenly declares a significant capital gain from the sale of an overseas property but cannot provide settlement documents or proof of ownership.
  
• A small business client with modest revenue asks you to prepare accounts showing inflated turnover in order to support a loan application.
  
• A high-net-worth individual provides you with large volumes of cash for “tax planning” but resists putting it through their own bank accounts, asking you to “hold” it temporarily.
  

Threshold Transaction Reports (TTRs)

When to lodge

You must submit a TTR whenever your practice receives cash or equivalent of AUD $10,000 or more in a single transaction or matter - even if it seems legitimate.

Relevant examples for accounting practices include:

• Cash deposits into your client or trust account
• Payment for accounting or advisory services made in cash
• Cash received for setting up or capitalising a company or trust
• Cash provided to your practice to cover tax liabilities or BAS obligations

You must lodge a report regardless of suspicion.

What to include

• Your firm's details (name, AUSTRAC ID, submission date).
• Staff details (who completed the report).
• Customer details (same level as SMRs – names, DOBs, addresses, business details, beneficial owners).
• Transaction details – date, time, location, amount, foreign currency info if relevant and the kind of designated service involved e.g. trust administration, company setup, tax service
• Accounts/products if involved – trust account number, opening dates, signatories, instruments (e.g. cheques).
• Purpose of the transaction (if known).
• If property related - unique reference number, value of the property, details of all involved, details of the property and any unique identifiers e.g. lot number

Exceptions

If cash is deposited via ATM/express deposit with no personal contact, or by a professional courier service, you don’t need to report the depositor’s details — but you must note the circumstances (e.g. “cash deposited via ATM, no personal contact”).

Accounting practice examples

• A client pays $15,000 in cash into your client account to cover their quarterly BAS and GST obligations.
• A business owner pays $12,000 in cash upfront for advisory services on restructuring their company.
• An individual pays $14,000 in cash to your practice to cover an outstanding ATO debt on their behalf.

Annual AML/CTF compliance reports

Each year, every reporting entity must submit a compliance report to AUSTRAC.

• Period covered: 1 January – 31 December.
• Due date: 31 March the following year (e.g. 2026 report due by 31 March 2027).
• Content: Shows how your firm is meeting obligations — AML/CTF Program in place, staff training, record-keeping, reporting, and independent reviews.
• Format: Online