As Australia prepares for the impending Tranche Two reforms, reporting entities across legal, accounting, real estate, and professional services need to understand their Suspicious Matter Reporting obligations.

SMR reports play a crucial role in safeguarding the financial system against illicit activity.

What is a Suspicious Matter Report (SMR)?

In simple terms, an SMR is a formal notice your organisation sends to AUSTRAC when something doesn’t add up.

An SMR must be submitted whenever you form a suspicion, based on reasonable grounds, that:

• the information you hold could relate to a criminal offence
• a client, prospective client, or someone acting on their behalf may not be who they claim
• a person may be seeking to use your services to commit, attempt or facilitate money laundering or terrorism financing.

This can extend to matters involving suspected tax offences, terrorism financing, money laundering, or other breaches of Commonwealth, state or territory law.

SMRs are lodged in good faith, and the intention is to provide AUSTRAC with intelligence that highlights transactions or conduct that appear unusual, inconsistent with expected behaviour, or potentially unlawful.

Your role is not to investigate or prove wrongdoing, only to recognise when something doesn’t look right and escalate it.

Why SMRs Matter

Suspicious matter reports are one of the most powerful tools regulators and law enforcement have for identifying financial crime.

When organisations lodge SMRs, they contribute to national intelligence efforts by helping authorities:

• map patterns of unusual financial activity
• identify potential criminal networks
• track the movement of illicit funds
• detect emerging threats before they escalate.

For professional services — especially accounting and legal practices — their involvement will significantly increase visibility into high-risk behaviours that may otherwise go unnoticed.

How quickly do you need to make the report?

The law sets strict submission timeframes, depending on the type of suspicion:

• Matters relating to possible terrorism-financing: must be reported within 24 hours of the suspicion arising
• All other suspicious matters: must be submitted within three business days
• If information subject to Legal Professional Privilege (LPP) is involved: businesses may have up to five business days to lodge the report, except where the matter relates to terrorism-financing, which always follows the 24-hour rule.

These deadlines ensure that the intelligence reaches AUSTRAC while it is still actionable.

Warning Signs Accountants Should Pay Attention To

As accountants begin operating under AML/CTF obligations, understanding the types of behaviour that may trigger an SMR will be crucial. Some warning signs include:

• transactions suspiciously structured to fall just below reporting thresholds
• international transfers or cash activity that don't fit the client’s business model
• requests to backdate, alter, or fabricate financial records
• shifting or unexplained justifications for transactions
• opaque ownership structures lacking commercial purpose
• refusal to provide identity, verification, or source-of-funds information
• transaction behaviour that clashes with industry norms or the client’s historical patterns.

Spotting these indicators early allows professionals to escalate appropriately, request additional information, and lodge an SMR where needed.

How Personr Can Help

As AML/CTF obligations expand to encompass the accounting, legal, and real-estate sectors, organisations will need smarter tools to manage compliance efficiently. 

Personr supports reporting entities by delivering automated, reliable, and AUSTRAC-aligned compliance solutions that simplify and strengthen your AML/CTF framework.

Learn more.

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