Obligations
Threshold transaction reports (TTRs): the A$10,000 cash rule every practice must operationalise
TTRs are the most mechanical obligation in the regime — and the easiest to breach by accident. Any designated-service transaction involving A$10,000 or more in physical currency must be reported to AUSTRAC within 10 business days. No suspicion required, no discretion: the report is about the cash, not the client.
What triggers a TTR
Electronic transfers, cards and cheques are not physical currency. But a client paying a A$14,000 invoice with A$9,000 by transfer and A$5,000 cash is under the threshold — while A$11,000 cash across three weekly instalments toward the same engagement is over it.
- Physical currency — notes and coins, Australian or foreign — of A$10,000 or more
- In a single transaction, or aggregated across related payments toward the same transaction
- Connected to a designated service you provide
The aggregation trap
Structuring — deliberately splitting cash to stay under the threshold — is exactly what TTRs exist to catch, and it is a red flag in its own right. Your program needs one simple rule for staff: total the cash connected to a matter, and when it reaches A$10,000, verify and report. Deliberately helping a client stay under the threshold can itself be an offence.
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 raise suspicion. The TTR does not need to be secret from the client; the SMR must be.
- 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), never disclosed to the client
Who feels this most
Dealers in precious metals and stones live inside this obligation — cash bullion and jewellery sales cross the threshold routinely. But accountants holding client money, conveyancers handling deposits and real estate agencies touching cash deposits all meet it too. Any practice whose answer is 'we never take cash' should write that policy down and train staff to escalate when a client produces it anyway.
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?
Yes — aggregated cash toward the same transaction reaches A$12,000. Verify as required and lodge the TTR within 10 business days of the transaction that took the total over the threshold.
Do we tell the client we lodged a TTR?
A TTR is a routine report and telling the client is not prohibited — unlike an SMR, which must never be disclosed. Many practices simply describe their cash reporting obligations up front in the engagement letter.
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.