Timely AML reporting obligations under the latest AUSTRAC guidance

In the evolving landscape of anti-money laundering (AML) and counter-terrorism financing (CTF), staying compliant with reporting obligations is paramount. AUSTRAC’s 2025 guidance places strong emphasis on businesses meeting their Part 9.9 reporting obligations with accuracy and timeliness. An infringement notice totalling $187,000 recently issued by AUSTRAC on a remittance service provider serves as a critical reminder of timely reporting and the regulatory consequences of failing to do so.

Late reporting hinders the ability of law enforcement to act swiftly in detecting and disrupting financial crime, in turn enabling them to pick up suspicious movements as soon as possible for criminal investigation. In this article, we break down what specific reports need to be submitted in a timely manner, what details they should consist of, and the consequences of reporting failures.

Understanding reporting requirements

Reporting entities are required to submit detailed reports on suspicious matters, threshold transactions and international funds transfer instructions. These reports must include comprehensive information about the entities involved, the nature of the transactions, and any previous reports that may be relevant.

For instance, suspicious matter reports (SMRs) must detail:

• The entity's full name
• The date the report is given
• Specifics about the suspicious activity.

Similarly, threshold transaction reports (TTRs), which is the transfer of $10,000 or more when providing a designated service, must capture the below details of the transaction:

• Date
• Time
• Value
• Parties involved.

International funds transfer instruction reports (IFTIs) must detail:

• The ordering customer’s full details
• The beneficiary customer’s full details
• Full transaction details
• The date of the instruction.

The importance of timeliness

One of the critical aspects is the timeliness of report submissions:

• SMRs must be submitted to AUSTRAC within three business days after a suspicious matter arises if the suspicion is in relation to money laundering and within 24 hours if the suspicion is in relation to terrorism financing. This ensures potential risks are promptly addressed
• TTRs must be submitted to AUSTRAC within ten business days of the transaction
• IFTIs must be submitted to AUSTRAC within ten business days of sending/receiving the instruction.

Adhering to these timelines is crucial to avoid regulatory scrutiny and potential penalties.

Consequences of late reporting

The guidance is clear on the repercussions of late reporting. Entities that fail to submit their reports within the specified timeframes may face significant fines and other regulatory actions. Voluntary late submissions of reports do not exempt a business from potential fines. This underscores the need for robust internal processes to ensure timely and accurate reporting. Businesses must prioritise compliance to mitigate the risk of penalties and maintain their standing with regulatory bodies.

BDO recommendation

As the regulatory environment continues to evolve, businesses must stay vigilant and proactive in their compliance efforts. The latest AUSTRAC guidance serves as a reminder of the importance of timely and accurate reporting in the fight against money laundering and terrorism financing. We recommend businesses understand and adhere to these requirements, which will ultimately safeguard their operations and contribute to a safer financial ecosystem.

How BDO can help

BDO is a trusted adviser to clients across a broad range of services and provides forensic services support, including preventative financial crime risk management. BDO’s forensic services team conduct AML/CTF independent reviews and financial crime risk assessments for highly regulated institutions to ensure they comply with their requirements under the AML/CTF Act, and that they have sufficient controls in place to prevent them from being the subject to costly fines and legal action.