AUSTRAC threshold transaction reports — the $10,000 cash rule

When a TTR is triggered

Section 43 of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) mandates that reporting entities submit threshold transaction reports (TTRs) to AUSTRAC. A threshold transaction occurs when physical currency is transferred, involving an amount of A$10,000 or more, or the foreign equivalent.

This threshold applies to various forms of cash transactions. These include, but are not limited to, cash deposits, cash withdrawals, cash exchanges and cash payments for designated services.

Reporting entities must submit a TTR for these transactions regardless of who is conducting them, including transactions involving walk-in customers. Bearer negotiable instruments are subject to a different reporting regime.

The 10 business day clock

Transaction Reports (TTRs) must be submitted to AUSTRAC within 10 business days following the transaction. These reports are to be lodged via AUSTRAC Online or through approved system-to-system integration. Failure to meet this timeframe constitutes a civil penalty contravention.

The 10 business day period begins on the business day immediately after the transaction occurred. This means the clock does not start on the day of the transaction itself.

Public holidays observed at the entity’s principal place of business are not included when calculating the 10 business day lodgement period.

What must be reported

The content of threshold transaction reports (TTRs) is prescribed by Chapter 19 of the AML/CTF Rules. These reports must include specific details relating to the transaction itself. This includes the amount and currency involved, the date the transaction occurred, the location of the transaction, and the designated service that was provided.

Alongside transaction details, TTRs require information about the customer. This includes the customer’s name, date of birth, and address. The report must also include a reference to the customer's verification documentation. If an agent acted on behalf of the customer, their details must also be included in the report. For more information on reporting obligations, see Suspicious matter reports — AUSTRAC.

It is important to note that attempting to avoid reporting requirements by breaking down or structuring cash transactions to remain below the $10,000 threshold is a separate offence under section 142 of the AML/CTF Act.

Penalties and enforcement

Failure to provide a threshold transaction report (TTR) constitutes a contravention of a relevant section of the legislation and may attract civil penalties of up to 100,000 penalty units per contravention. Providing a TTR that is knowingly false or misleading can lead to criminal prosecution. AUSTRAC IFTI — international funds transfer instructions are also subject to similar reporting obligations.

AUSTRAC regularly publishes details of enforcement outcomes, demonstrating its commitment to compliance. A notable example is the 2020 settlement with Westpac, which involved a substantial payment for systemic failures in both TTR and AUSTRAC IFTI — international funds transfer instructions reporting.

Operating a business providing designated services without a valid AUSTRAC enrolment is an offence in itself. Furthermore, TTR data is shared with law enforcement agencies via a financial intelligence channel to support investigations.