A threshold transaction report is what you send AUSTRAC when a designated service you provide involves a transfer of $10,000 or more in physical currency. Notes and coins. The same threshold applies to foreign currency worth $10,000 or more in Australian dollars.
It runs in both directions. Cash you receive and cash you pay out both count.
You have 10 business days after the day the transaction takes place, and the obligation is automatic. Nobody asks you for it.
Values do not add up, and this is where most guidance is wrong
Read enough compliance material and you will find advice that related cash transactions totalling $10,000 or more within 24 hours have to be reported. That is not what the AUSTRAC guidance says.
Each physical currency transaction is treated separately. A transaction is a single payment, even where it covers several services. AUSTRAC states directly that you do not combine the value of separate transactions even if they happened quickly or at another location.
Its own examples make the point sharply. A customer buying a $20,000 bracelet who pays it off in $2,000 cash instalments over a month generates no TTR at all. A customer buying $7,000 of euros and $7,000 of pounds at the same counter at the same time generates none either.
A firm running a rule that sums a client’s cash across a week is reporting things the Act does not ask for, which is its own kind of problem, and it is probably still missing the thing that actually matters.
The absence of a TTR is where the real question starts
Every one of those AUSTRAC examples ends the same way. No TTR required, and then: consider whether a suspicious matter report is needed.
Structuring is dividing large cash transactions into smaller ones to get under the threshold. It is a criminal offence, and spotting it is a monitoring obligation rather than a reporting threshold. If you have reasonable grounds to suspect a customer is doing it, you must submit an SMR, and if you keep providing the service you must apply enhanced due diligence.
AUSTRAC’s real estate example is worth reading twice, because it is the one most likely to walk into a Tranche 2 firm. A buyer agrees to a $50,000 deposit and asks to pay it as 5 amounts of $9,000 plus 1 of $5,000. The agent asks why. The buyer becomes irritated and gives no reason. That is reasonable grounds, and the agent submits an SMR.
Note what did the work there. Not a threshold. A question, and a person paying attention to the answer.
The threshold is the transaction, not the price
A small but expensive detail. AUSTRAC’s example has a customer paying out a $9,800 loan balance in cash, which is under the threshold, until the bank adds a 2.5% early repayment fee. The amount payable becomes $10,045 and the customer pays that in cash. A TTR is required.
Fees, adjustments and add-ons that go into the same payment count towards the $10,000. If your front desk is checking the invoice figure rather than the amount actually handed over, it will miss cases like this.
When the transaction takes place is not when the deal completes
The 10 business days run from the day the transaction takes place, and for property that is rarely settlement.
In AUSTRAC’s example a buyer hands a real estate agent $21,250 in cash as a deposit on day one, signs the contract a week later, and settles 6 weeks after that by electronic transfer into the trust account. The threshold transaction happened on day one. The TTR is due within 10 business days of that, not of settlement, and the electronic settlement payment needs no second report.
Which means the clock can be most of the way through before anyone in the firm has opened a file. If your trigger for compliance work is the contract rather than the money, you are already late. This is the same structural problem that makes holding client money harder than it looks.
Tranche 2 firms must use the new form
Existing reporting entities got a choice. From 1 July 2026 to 30 March 2029 they can keep using the old TTR form or move to the new one, and the old form asks for less.
That choice is only available to businesses that were on the Reporting Entities Roll on 30 March 2026. A firm that became a reporting entity when table 6 commenced on 1 July 2026 was not on it, so the new form is compulsory from the start.
This is the same pattern as the initial CDD transitional rules, where the 3 year concession is also closed to newly regulated firms. It is worth internalising as a general rule: transitional relief in this reform package was written for the entities that already had systems, not for the ones that do not.
What the new form wants, and why it has to be captured at the counter
The new form is considerably more demanding than the old one. Beyond the obvious details of your business, the customer and the amount, it asks for:
- every other party to the transaction, including counterparties, agents, trustees and beneficial owners
- where someone acts on behalf of a customer, a description of the relationship and of their authority to act
- where and when the transaction took place, the role of each party, and the purpose of the transaction if known
- account details including type, unique identifiers and the date the account was opened
- the instruments used, such as cheques, gaming chips, shares, stored value cards or precious metals
- for services provided online, network identifiers such as IP address and device identifiers, if known
Most of that cannot be reconstructed on day 9. The purpose of the transaction, the authority under which somebody was acting, who else was in the room: those are things you either asked at the time or you did not.
So the practical design point is that a TTR is a capture task with a report on the end of it, and the capture happens at the counter rather than in the compliance file 9 days later.
The exemptions are not for you
Section 44 carries a short list: services provided through a permanent establishment in a foreign country, certain arranging services, dealings between authorised deposit-taking institutions, and transactions where both parties use exchange settlement accounts.
There is no professional services exemption and no small business exemption. An accounting practice, a law firm or an agency that takes $10,000 in cash reports it, no matter how rarely that happens.
A lot of firms respond by setting an internal cash cap below the threshold. That is a legitimate business decision and it removes the reporting question entirely. It does not remove the monitoring question, because a client who wanted to pay cash and now cannot is still information about that client.
A short checklist
- Decide whether your firm accepts physical currency at all, and put the answer in writing.
- If it does, make the trigger the amount handed over, including fees and adjustments, not the invoice total.
- Capture the reportable details when the cash changes hands, because the new form asks for things you cannot recover later.
- Diarise 10 business days from the transaction date, not from contract or settlement.
- Train reception and trust account staff on structuring patterns, since they see the behaviour before anyone else does.
- Keep the records. Reporting and record keepingare separate obligations and the second one outlives the first.
Tracking cash triggers, the 10 day clock and the customer file in the same place is what HP-KYC was built to do.
Frequently asked questions
Does a TTR mean I am accusing my client of something?
No. A threshold transaction report is a routine report about the size and form of a payment, not a suspicion. Accepting a large cash payment is lawful provided you have completed customer due diligence and lodge the report on time. The report that carries suspicion is a suspicious matter report, which is a separate obligation with separate rules.
Do I add up several cash payments from the same client?
No. AUSTRAC treats each physical currency transaction separately, and says you do not combine the value of separate transactions even where they occur close together or in different places. What you do have to do is watch for a client splitting payments deliberately to stay under the threshold, which is structuring and calls for a suspicious matter report.
How long do I have to lodge a TTR?
10 business days after the day the transaction takes place. For a property deposit paid in cash, that clock starts on the day the cash changes hands, not at exchange or settlement.
Does the $10,000 threshold include foreign currency?
Yes. The threshold applies to foreign physical currency of the same value, converted to Australian dollars. Your report has to state both the Australian dollar value and the amount and type of foreign currency involved.
Do TTRs apply to bank transfers and card payments?
No. The threshold transaction obligation is limited to physical currency, meaning notes and coins. An electronic transfer of any size does not generate a TTR, though other reporting obligations can apply to international transfers and any transaction can give rise to a suspicious matter report.
Can Tranche 2 firms keep using the old TTR form?
No. The option to continue with the pre-reform form until 30 March 2029 is only open to businesses that were on the Reporting Entities Roll on 30 March 2026. Firms newly regulated from 1 July 2026 use the new form from the beginning.
The technical detail
Core obligation. Section 43(1), Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), read with the definition of threshold transaction in section 5. Applies where a designated service involves the transfer of $10,000 or more in physical currency, or the equivalent value in foreign physical currency, whether received or paid.
Deadline. Section 43(2). Within 10 business days after the day the transaction takes place.
Reportable details. Rules sections 9-6, 9-7 and 9-8, with the full list at Division 2 of Part 9 of the AML/CTF Rules. Covers the reporting business, the individual completing or accountable for the report, the customer, other parties including counterparties, agents, trustees and beneficial owners, the relationship and authority of any person acting on behalf of a customer, transaction time and place, party roles, purpose where known, Australian dollar value, foreign currency amount and type, designated services provided, account type and identifiers and opening date, instruments used, property transferred, virtual asset type and wallet addresses, and for online services the network and device identifiers and the time of the online activity.
Form transition. Rules section 12-3. Reporting entities on the Reporting Entities Roll on 30 March 2026 may use either the pre-reform form or the new form from 1 July 2026 to 30 March 2029. Entities not on the Roll on that date must use the new form from 1 July 2026.
Remittance network providers. Section 49A and Rules sections 9-10(3). An RNP submits TTRs for threshold transactions carried out by its affiliates.
Structuring. Sections 142, 30(5), 32(b) and 41. Dividing cash transactions to avoid threshold reporting is a criminal offence. Reasonable grounds to suspect structuring triggers an SMR obligation, and continuing to provide the designated service triggers enhanced customer due diligence.
Exemptions. Section 44(5) to (8). Designated services provided at or through a permanent establishment in a foreign country, other than for a remittance network provider; certain arranging services; services provided by one authorised deposit-taking institution to another; and transactions where the reporting entity and the customer both use exchange settlement accounts.
Commencement. Table 6 professional services became designated services on 1 July 2026. Reformed obligations commenced 31 March 2026 for existing reporting entities. Penalty unit $364 from 1 July 2026.
