When to report
A reporting entity must submit a suspicious matter report when the criteria in the AML/CTF Act are met. AUSTRAC's guidance covers suspicions connected with money laundering, terrorism financing, tax evasion and other serious offences. A report is based on reasonable grounds for suspicion; staff do not need to prove a crime before escalating the matter for assessment.
Which deadline applies
The submission window depends on the suspicion and, in one case, the information in the report. AUSTRAC says an SMR related to terrorism financing is due within 24 hours of forming the suspicion. Other suspicions are generally due within three business days after the day the suspicion was formed. Where the report includes information protected by legal professional privilege, AUSTRAC describes a five-business-day window, except for terrorism-financing suspicions. A workflow should surface the applicable deadline for human review rather than assume every matter follows the same clock.
Protecting SMR information
AUSTRAC's tipping-off guidance says disclosure of protected SMR-related information is prohibited where it would or could reasonably be expected to prejudice an investigation. Access to an SMR workflow therefore needs deliberate controls and a documented disclosure process. Whether information can be shared in a particular case should be assessed against the current law and AUSTRAC guidance.
A workable escalation
An email-based escalation can leave important questions unanswered: when was the suspicion formed, who is reviewing it, which deadline applies, and has a report actually been submitted? A structured workflow can make those facts visible, restrict access and retain the decision history. The organisation still needs trained people, an agreed reporting process and a way to deal with matters outside ordinary hours.
Check the current process
Since 1 July 2026, businesses in newly covered sectors that provide designated services have had AML/CTF obligations, including suspicious matter reporting where the reporting criteria are met. The first suspicious matter is a poor time to discover that an escalation exists only in someone's inbox. A reporting entity should check its current reporting process against AUSTRAC's guidance and its own program, including who can see sensitive information, who decides what happens next, and how the submission is recorded.