What triggers a TTR
Electronic transfers, cards and cheques are not physical currency. A client paying an A$14,000 invoice with A$9,000 by transfer and A$5,000 cash is under the threshold. Three separate cash instalments that total A$11,000 also do not create a TTR unless one individual physical-currency transaction is at least A$10,000; the pattern may still require suspicious-matter review.
- Physical currency — notes and coins, Australian or foreign — of A$10,000 or more
- In a single physical-currency transaction; separate payments are not aggregated for the TTR threshold
- Connected to a designated service you provide
The structuring trap
Do not combine separate cash payments merely to create a TTR. Instead, monitor linked activity so deliberate splitting, or structuring, is escalated for suspicious-matter review. If an individual physical-currency transaction reaches A$10,000, lodge the TTR; if the pattern creates a suspicion, follow the separate SMR process and do not tip off the customer where disclosure could prejudice an investigation.
The 10-business-day clock
TTRs are due within 10 business days of the transaction. Business days exclude weekends and public holidays in the relevant jurisdiction — a deadline that is easy to miscalculate around Easter or the summer shutdown. Record the transaction date, compute the due date when the cash arrives, and do not leave the calculation to memory.
TTR vs SMR: do not confuse the two
A large cash transaction can require both: the TTR because the cash crossed the threshold, and an SMR if the circumstances also create reasonable grounds for suspicion. TTR obligations can be explained in ordinary customer communications. Do not disclose protected SMR-related information where disclosure would or could reasonably be expected to prejudice an investigation; use genuine CDD and service communications that do not reveal the suspicion.
- TTR: mechanical, triggered by cash volume alone, 10 business days, no suspicion needed
- SMR: judgment-based, triggered by suspicion, 3 business days (24 hours for terrorism financing), with protected information subject to the prejudice-based tipping-off prohibition
Who feels this most
Dealers in precious metals and stones need both regulated-service and reporting controls: bullion is separately designated, while non-bullion precious items use the physical-currency or virtual-asset threshold. Accountants, conveyancers and real estate businesses should separately assess any cash-reporting exposure relevant to their own designated services.
Official sources
Use these primary AUSTRAC pages to confirm the current rules and apply them to your circumstances.
Frequently asked questions
Does a bank cheque count as physical currency?
No. Physical currency means notes and coins. Bank cheques, transfers and card payments do not count toward the TTR threshold — though unusual use of them can still be relevant to suspicion.
The client paid A$8,000 cash last month and A$4,000 cash this month for the same matter. TTR?
Not on those facts: neither individual physical-currency transaction reached A$10,000, so the payments are not combined to create a TTR. You must still assess whether the splitting is structuring or otherwise suspicious and lodge an SMR within the applicable deadline if a suspicion forms.
Do we tell the client we lodged a TTR?
A TTR is a routine report and the AML/CTF tipping-off offence does not generally prohibit describing cash-reporting obligations. SMR-related information is different: do not disclose protected information where that would or could reasonably be expected to prejudice an investigation. Other confidentiality and privacy duties may still apply.
Put it into practice
Cassandra AML turns these obligations into a working system: designated-service decisions, customer due diligence, screening, monitoring and reporting records — hosted in Sydney, free to start.
This guide is general information for Australian professionals. It is not legal advice and does not replace the AML/CTF Act, the AML/CTF Rules or AUSTRAC guidance. Confirm your specific obligations with AUSTRAC or a qualified legal adviser. See our editorial and correction standards.