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AUSTRAC has made it mandatory for reporting entities to include a threshold transaction report (TTR) for cash transactions of over AU$10,000.
The current transaction reporting guidance from AUSTRAC enlists the requirement of reporting with TTRs. However, it is up to the reporting entity to determine whether a certain number of services provided to customers summing up to AU$ 10,000 (or more) are supposed to be treated as single or multiple transactions.
According to the new draft guidance, the requirement for combining multiple transactions while submitting TTRs will be discarded, as a TTR will be mandatory for each individual transaction of more than AU$10,000.
The proposed updated guidance says, “If you suspect your customer is structuring their transactions to avoid the TTR reporting threshold you must submit a suspicious matter report (SMR) to AUSTRAC.”
In the cases where customers make multiple cash transactions, every individual transaction is to be considered a distinct and separate designated service. Even when multiple transactions are made within a short interval of time, reporting entities will not need to merge them into one for the purpose of submitting a TTR.
Addressing the reporting entities, the proposed guidance suggests, “You must consider whether your customer has a reasonable explanation for conducting multiple transactions, or whether this activity is suspicious.”
AUSTRAC has provided a 12-month transition period acknowledging the need for reporting entities to update their systems and conduct staff training for fulfilling the new requirements.
The suggested updates in the guidance are reportedly open for comment until 22 December, after which AUSTRAC will provide a conclusive TTR guidance in the beginning of 2022.
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