Threshold Transaction Reports

A Threshold Transaction Report (TTR) gives AUSTRAC information about a large transfer of physical currency. The obligation is specific: it applies when a reporting entity provides a designated service that involves transferring physical currency worth A$10,000 or more. The report is due within 10 business days after the transaction.

Who has a TTR duty

A business has a TTR duty when it is a reporting entity under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 and the threshold transaction occurs through a designated service it provides. Reporting entity status depends on the services provided and the circumstances in which they are provided.

A business does not become responsible for TTRs merely because it accepts a large cash payment. Its first step should be to identify its designated services and determine which of them can involve a transfer of physical currency. That service mapping should inform procedures, staff training and transaction controls.

The A$10,000 physical currency threshold

The threshold covers a single transfer of Australian banknotes or coins with a value of A$10,000 or more. It also covers a single transfer of foreign banknotes or coins with an Australian dollar value of A$10,000 or more. The amount includes exactly A$10,000.

For foreign currency, the reporting entity should use a consistent exchange rate applicable at the time of the transfer and retain the rate or method used. Payments by card, cheque, account transfer or digital asset do not meet the physical currency test merely because their value exceeds A$10,000.

Each transfer is assessed separately

Several sub-threshold transfers are not added together to create TTRs. For example, two separate cash transfers of A$6,000 do not become two threshold transactions because their combined value is A$12,000. Each transfer remains below the TTR threshold. The pattern may still warrant closer review under the reporting entity's transaction monitoring and suspicious matter procedures.

The 10 business day deadline

A reporting entity must lodge the TTR within 10 business days after the transaction occurs. The workflow should record the transaction date, calculate the due date and assign responsibility as soon as the threshold is detected. Weekends and applicable public holidays should be handled consistently with the legal meaning of a business day. Internal review should leave enough time to correct data before lodgement.

Information and workflow

A TTR needs accurate information about the reporting entity, the transaction and the people or organisations involved. Depending on the transaction, this commonly includes:

• Record the date, time, location, amount, currency and type of transaction.
• Identify the designated service and any relevant account or reference details.
• Identify the customer and the person conducting the transaction.
• Record any person or organisation on whose behalf the transaction is conducted.
• Include the identity information and document details held by the reporting entity.
• Add recipient or beneficiary details where they are relevant.

A practical workflow starts when the cash transfer is captured. The system or staff member flags the amount, confirms that the transaction concerns a designated service, records the required details and opens a report with a due date. A reviewer then checks names, dates, identifiers, currency values and account references against source records. After lodgement through AUSTRAC's reporting channel, the reporting entity should retain the submission receipt, supporting records and evidence of any correction.

TTRs and suspicious matter reports

A TTR is amount based. It is required for a qualifying transfer even when the activity appears consistent with the customer's known circumstances. A suspicious matter report (SMR) depends on reasonable grounds for suspicion and follows separate content, timing and confidentiality rules.

The same transaction can require both reports. A TTR does not satisfy an SMR obligation, and an SMR does not remove a TTR obligation. Staff should therefore complete the threshold check and the suspicious matter assessment as separate decisions. Information about an SMR must be handled in accordance with the tipping off restrictions.

Structuring red flags

Structuring involves arranging transactions to avoid a reporting threshold. Indicators can include repeated cash transfers just below A$10,000, use of several locations or people, an abrupt change from the customer's usual activity, or explanations that conflict with available records. These indicators require assessment in context. They do not convert sub-threshold transfers into TTRs. If the facts provide reasonable grounds for suspicion, the reporting entity should follow its escalation process and consider its SMR obligation.

Practical example

A currency exchange business that is a reporting entity accepts A$12,400 in Australian banknotes from a customer as part of a designated foreign exchange service. The transfer exceeds the threshold, so the business records the customer, identity and transaction details and lodges a TTR within 10 business days.

If the customer instead conducts two separate A$6,200 cash transfers, neither transfer independently reaches A$10,000 and neither requires a TTR on amount alone. If the timing, behaviour or explanation suggests that the customer divided the activity to avoid reporting, the business reviews the full circumstances and decides whether an SMR is required.