Identify the type of transaction
A threshold transaction report (TTR) concerns a designated service involving a transfer of $10,000 or more in physical currency. The equivalent foreign-currency value also qualifies.
Physical currency means notes and coins. It includes receiving or paying cash. A large electronic transfer is not a cash threshold transaction.
Submit a required TTR within 10 business days after the transaction day. Apply sections 43 and 44, including the service conditions and exemptions.
Sources: AUSTRAC: Threshold transaction reporting; Federal Register of Legislation: Sections 6, 41, 43 and 47; Part 3.
- Physical currency
Distinguish notes and coins from electronic transfers.
- Threshold and conditions
Examine the $10,000 threshold or relevant foreign-currency equivalent, service and exemptions.
- Separate suspicion review
Assess any suspicious activity independently of the cash threshold.
Examine the payment facts before the reporting route
Read the transaction conditions and exemptions. Separate payments have separate TTR treatment. Amounts below the threshold can still raise suspicion.
Decision checkpoints. Read the conditions for each point in the text below.
Capture the facts before classifying
A practical intake record can identify the service, transaction date, currency, amount, customer and person presenting the money. It can also distinguish cash from an electronic payment or another instrument. These fields help the reviewer ask the right reporting question. The operating instruction should state where exchange-rate evidence comes from when needed. A statement that a payment was large is not enough to establish its classification.
The reviewer needs the underlying payment facts and a traceable decision about the applicable reporting route.
Sources: AUSTRAC: Threshold transaction reporting; Federal Register of Legislation: Sections 6, 41, 43 and 47; Part 3.
Invented example: two different payments
Imagine a business receives one large bank transfer and a separate cash payment while providing a covered service. The example reviewer does not merge their labels merely because both appear in the same customer account. The reviewer identifies the physical-currency transaction and applies the relevant TTR rules. The bank transfer can still be relevant to other controls. If the surrounding behaviour raises questions, the reviewer considers it through the monitoring process.
The example illustrates classification. It does not resolve every linked-transaction scenario.
Sources: AUSTRAC: Threshold transaction reporting; Federal Register of Legislation: Sections 6, 41, 43 and 47; Part 3.
Keep suspicion separate from the threshold
AUSTRAC treats separate physical-currency payments as separate transactions. It does not require their amounts to be combined merely because they occur close together.
One payment can cover multiple services. Identify the actual transaction before applying the threshold. A required TTR does not depend on suspicion.
A pattern of smaller payments can still warrant an SMR assessment. Record the reporting decisions separately. A TTR threshold is not a safe amount for suspicious activity.
Splitting cash payments to avoid a threshold report can be the structuring offence in section 142 of the Act. Where the business suspects that purpose on reasonable grounds, apply the SMR conditions. The structuring guide explains the test.
Sources: AUSTRAC: Multiple physical currency transactions; Federal Register of Legislation: Section 142, including subsection (2); section 5 threshold transaction; AUSTRAC: Threshold transaction reporting; Structuring; AUSTRAC: Definition; AUSTRAC: Overview; AUSTRAC: Money laundering methodologies: structuring.
Examine the reporting evidence
An illustrative final check reconciles the report data with the source transaction record. It examines the customer details, cash amount, currency and reporting reference. A second person can review a sample for classification errors, such as electronic transfers incorrectly marked as cash. The business should also confirm the correct current form and its reporting timetable with AUSTRAC guidance. This proposed check supports accurate operations but does not confirm compliance.
Retain the evidence needed to describe why a transaction was reported or assessed as outside this reporting route.
Sources: AUSTRAC: Threshold transaction reporting; Federal Register of Legislation: Sections 6, 41, 43 and 47; Part 3.