What counts as a suspicion
You do not need evidence. A reasonable suspicion on reasonable grounds is enough. Typical triggers for an accounting firm:
- Funds that do not match the client's known income or business.
- Reluctance to explain the source of funds, or explanations that change.
- Unusual use of cash, or requests to structure payments under AU$10,000.
- A third party funding or directing the matter for no clear reason.
- Complex structures with no commercial purpose.
- A client who refuses identification or offers documents that look wrong.
How to lodge
- Record the suspicion in your own system the day it forms: what you saw, when, who noticed. This starts your timeline.
- Lodge the SMR through AUSTRAC Online within 3 business days (24 hours for terrorism financing).
- Rate the client high risk and apply enhanced due diligence, or decide not to continue.
- Keep the record for 7 years.
Tipping off
Do not tell the client, or anyone outside the firm, that you have lodged or are considering an SMR, where doing so could prejudice an investigation. The reformed rule focuses on that harm, but the safe practice in a small firm is simple: discuss it only with your compliance officer and AUSTRAC.
You can still act for the client
Lodging an SMR does not by itself require you to stop acting. It requires you to report, to reassess the risk and to keep watching.
Questions people ask
- What if I am wrong?
- Reporting a suspicion in good faith is protected. Not reporting one is the breach.
- Does the 3 days include weekends?
- No. Business days exclude weekends and national public holidays.
This guide is general information for accountants, bookkeepers, BAS agents, not legal advice. Check AUSTRAC's current guidance for your situation.