Threshold Transaction

A customer walks into your business with $10,500 in cash. They want to deposit it, exchange it, or use it to buy something. You process the transaction.

Then what? You report it to AUSTRAC. Because that's a threshold transaction — and reporting them isn't optional.

What Is a Threshold Transaction?

A threshold transaction is any transaction involving physical currency of $10,000 or more (or the foreign currency equivalent).

The key word: physical currency. Cash. Notes. Coins. Not bank transfers. Not credit cards. Not cheques. Physical money.

If someone gives you $10,000 or more in cash in a single transaction, you file a Threshold Transaction Report (TTR) with AUSTRAC within 10 business days.

Why $10,000?

The threshold isn't arbitrary. It's set at a level where:

• Large enough to catch significant ML/TF activity
• Low enough that criminals can't move huge amounts without triggering reports
• Aligned with international standards (FATF recommendations)

Most legitimate businesses don't deal in $10,000+ cash regularly. If someone's paying that much in physical currency, AUSTRAC wants to know about it.

What Counts as "Physical Currency"?

Includes:

• Australian dollars (notes and coins)
• Foreign currency (USD, EUR, GBP, etc.)
• Travelers cheques
• Money orders (if paid for with cash)

Excludes:

• Bank transfers
• Credit card payments
• Debit card payments
• Cheques (personal or bank cheques)
• PayPal or other digital payments
• Cryptocurrency (separate reporting regime)

So if someone buys a $50,000 car with a bank transfer? No TTR required. Same car paid for with $50,000 in cash? You're filing a TTR.

Single Transaction vs Multiple Transactions

Single transaction of $10,000+: Straightforward. Report it.

Multiple transactions that total $10,000+: This gets tricky.

If the same customer makes multiple cash transactions on the same day that total $10,000 or more, you need to report each transaction separately as a TTR.

Example:
Customer deposits $6,000 in cash at 10 AM.
Same customer deposits $5,000 in cash at 2 PM.
Total: $11,000.

You file two TTRs — one for the $6,000 transaction, one for the $5,000 transaction. Both reports note that they're part of a series totaling over $10,000.

But what about transactions on different days?

If you have reasonable grounds to believe multiple transactions (even across different days) are linked and deliberately structured to avoid the threshold, that's not just TTR territory — that's suspicious matter report (SMR) territory. Because it's smurfing.

When Do You Report?

Deadline: 10 business days from when the transaction occurred.

Not 10 calendar days. Not 2 weeks. 10 business days.

Transaction happens Monday. You count: Tuesday (1), Wednesday (2), Thursday (3), Friday (4), Monday (5)... by the second Friday (10th business day), your TTR needs to be lodged with AUSTRAC.

Late reporting? That's a breach. AUSTRAC can (and does) impose penalties for systematic late TTR submissions.

What Goes in a TTR?

AUSTRAC's TTR form asks for:

Transaction details:

• Date and time
• Amount (exact to the dollar)
• Currency type (AUD, USD, EUR, etc.)
• Type of transaction (deposit, withdrawal, exchange, purchase)

Customer details:

• Full name
• Date of birth
• Address
• Identification details (passport, driver's license number)

Your business details:

• Your name/entity name
• Account number (if applicable)
• Branch location

If you don't have all the customer details (maybe they're a walk-in customer), you report what you do have. But you should be trying to collect ID for large cash transactions anyway (it's part of CDD).

TTRs vs SMRs: What's the Difference?

Threshold Transaction Report (TTR)
- Automatic. Every cash transaction $10,000+.
- Reported within 10 business days.
- No suspicion required. Just the fact that it happened.
- You can complete the transaction and tell the customer you're reporting it (because it's automatic, not suspicion-based).

Suspicious Matter Report (SMR)
- When you suspect money laundering or terrorism financing.
- Reported within 3 business days (or 24 hours for TF).
- Based on your assessment of red flags.
- You cannot tell the customer (tipping off).

Can you file both? Absolutely. In fact, it's common.

Customer deposits $15,000 cash. You file a TTR (because it's over $10,000). But the customer's a student with no known income, and they can't explain where the money came from. You also file an SMR (because it's suspicious).

Who Needs to File TTRs?

Not every business files TTRs. Only certain reporting entities:

Banks and financial institutions: Yes
Money transfer businesses: Yes
Currency exchange providers: Yes
Casinos: Yes
Bullion dealers: Yes (for cash transactions $10,000+)

Lawyers and accountants (Tranche 2): Maybe
TTR obligations for Tranche 2 entities depend on the specific service. If you're receiving cash as part of a designated service and it's $10,000+, you'll need to check if TTR reporting applies to your sector.

Real estate agents (Tranche 2): No
Real estate agents generally don't file TTRs because they're not directly receiving cash — it goes through lawyers' trust accounts or bank transfers.

The $10,000 Myth: Foreign Currency

Common misconception: "The threshold is $10,000 AUD, so if I accept $8,000 USD, I don't need to report it."

Wrong. The threshold is $10,000 or foreign currency equivalent.

$8,000 USD converts to approximately $12,000 AUD (depending on exchange rates). That's over the threshold. You report it.

AUSTRAC wants you to use the exchange rate applicable at the time of the transaction. You document which rate you used and report accordingly.

Structuring: When Customers Try to Avoid the Threshold

Criminals know about the $10,000 threshold. So they structure transactions to stay just under it:

Example:
Monday: Deposit $9,500
Tuesday: Deposit $9,800
Wednesday: Deposit $9,000
Total: $28,300

Each individual transaction is under $10,000, so no automatic TTR triggers. But the pattern is obvious: they're deliberately avoiding the threshold.

That's structuring (also called smurfing), and it's a massive red flag.

When you spot it, you don't just skip the TTR because each transaction is under $10,000. You file an SMR explaining the structuring pattern.

What AUSTRAC Does with TTRs

AUSTRAC receives millions of TTRs every year. They don't investigate every single one. Instead, they:

Build intelligence profiles
Who's moving large amounts of cash? Where are they moving it? Are there patterns?

Cross-reference with other data
Your TTR alone might look innocent. But combined with SMRs from other banks, international fund transfer reports, and tax data, it might reveal a money laundering network.

Feed investigations
When law enforcement is investigating someone, they query AUSTRAC's data. Your TTRs provide the transaction history they need for prosecution.

Detect anomalies
Machine learning algorithms flag unusual patterns across millions of TTRs. Someone suddenly moving 10x more cash than usual? Flagged for review.

Common TTR Mistakes

Mistake 1: Not aggregating same-day transactions
Customer makes three $4,000 cash deposits in one day. Total: $12,000. You need to report all three as TTRs.

Mistake 2: Only reporting when it "looks suspicious"
TTRs are automatic. Every cash transaction $10,000+ gets reported, whether it looks suspicious or not.

Mistake 3: Forgetting foreign currency conversions
€7,500 might sound under the threshold, but it converts to over $10,000 AUD. Convert and report.

Mistake 4: Filing late
"I'll batch them all and submit monthly." Nope. 10 business days. For each transaction.

Mistake 5: Not collecting customer details
"They paid cash, so I don't need their ID." Wrong. Large cash transactions require identity verification.

Exemptions: When TTRs Aren't Required

Certain transactions are exempt from TTR reporting:

Withdrawals from customer's own account
If a customer withdraws $10,000+ cash from their own bank account, the bank might not need to file a TTR (depends on the specific circumstances and exemptions applied).

Foreign exchange exemptions
Licensed currency exchange providers can apply for exemptions for certain transaction types.

But: Exemptions are specific and must be granted by AUSTRAC. You can't just decide a transaction is exempt. If you're unsure, file the TTR.

Penalties for Non-Reporting

Failing to file TTRs is a breach of the AML/CTF Act. Penalties:

Civil penalties: Up to $22.2 million per breach for corporations, $4.44 million for individuals.

But it's not just about one missed TTR. If you're systematically failing to file TTRs, each transaction is a separate breach. Miss 100 TTRs? That's 100 breaches. The penalties compound.

Real case: Commonwealth Bank's $700 million penalty included failures to file over 50,000 TTRs from their intelligent deposit machines. Customers were depositing cash, transactions exceeded $10,000, TTRs weren't being generated. AUSTRAC hit them with massive penalties.

Technology for TTR Compliance

Manual TTR tracking doesn't scale. If you're processing hundreds of cash transactions daily, you need automated systems that:

• Flag transactions at or approaching $10,000
• Aggregate same-customer transactions on the same day
• Convert foreign currency automatically
• Collect customer details at point of transaction
• Generate TTR reports in AUSTRAC's required format
• Track submission deadlines (10 business days)

Most banks and financial institutions have core systems that handle TTR reporting automatically. Smaller businesses (currency exchange, bullion dealers) might need standalone AML software.

Tranche 2 and TTRs

For Tranche 2 entities coming into the AUSTRAC regime in July 2026:

Lawyers: If you're receiving $10,000+ cash into your trust account as part of a designated service, you'll need to assess if TTRs apply. AUSTRAC guidance will specify.

Accountants: Generally won't be dealing with large cash amounts, so TTRs less common. But if you do receive $10,000+ cash, check your obligations.

Precious metals dealers: Absolutely. If someone buys $10,000+ worth of gold with cash, you file a TTR.

The key: Read AUSTRAC's sector-specific guidance for your profession. TTR obligations vary based on the service you're providing.

The Bottom Line

Threshold transaction reporting is straightforward: Cash transaction of $10,000 or more? Report it to AUSTRAC within 10 business days.

Don't overthink it. Don't try to assess whether it's "suspicious enough" to report. If it's cash and it's $10,000+, file the TTR.

And if you notice patterns — multiple transactions just under $10,000, customers who consistently bring large cash amounts, anything that doesn't make sense for their profile — that's when you file an SMR on top of the TTR.

Because TTRs aren't about catching criminals directly. They're about creating a data trail that AUSTRAC and law enforcement can use to identify ML/TF patterns across the financial system.

Your individual TTR might seem insignificant. But combined with thousands of others, it helps detect and disrupt serious crime.