Cash Over $10,000: The Threshold Transaction Report (TTR) Obligation
If you receive $10,000 or more in physical currency, you must file a Threshold Transaction Report (TTR) with AUSTRAC. This is a strict liability obligation - no suspicion required.
What is a TTR?
A Threshold Transaction Report (TTR) is a mandatory report filed under Section 43 of the AML/CTF Act whenever you receive or disburse $10,000 or more in physical currency (cash).
Key point: "Cash" means physical currency
TTR obligations apply to physical currency (notes and coins) only. Electronic transfers, cheques and card payments do not trigger TTR requirements - even if they exceed $10,000.
When does the obligation apply?
TTR Required
- $10,000+ in Australian dollars (cash)
- Foreign currency equivalent to $10,000+ AUD
- Multiple cash payments that total $10,000+ and are reasonably connected
TTR Not Required
- Electronic bank transfers (any amount)
- Cheque payments (any amount)
- Credit/debit card payments
- BPAY or direct debit
The 10-business-day deadline
You must file a TTR within 10 business days of the transaction occurring. Unlike SMRs, there is no discretion here - it is an automatic reporting requirement.
Counting the deadline
The 10-day period is counted in business days (excluding weekends and public holidays). If you receive $15,000 cash on a Friday, day one is the following Monday.
What to include in a TTR
- Transaction details: Date, amount, currency
- Client identification: Name, address, date of birth, ID document details
- Transaction type: Whether received or disbursed
- Purpose: Brief description of the transaction purpose
- Your business details: Your reporting entity information
Structuring: The $10,000 workaround (illegal)
Some clients may attempt to avoid TTR reporting by splitting cash payments into amounts below $10,000. This is called "structuring" and is a criminal offence under Division 5, Part 12 of the AML/CTF Act.
If you suspect structuring - a red flag
If a client appears to be structuring transactions to avoid the $10,000 threshold, you should file an SMR (Suspicious Matter Report) in addition to any TTR obligations. Structuring is a red flag for money laundering.
Practical sectors affected
TTR obligations are most relevant for:
- Jewellers and precious metal dealers: Often deal in high-value cash transactions
- Real estate agents: May receive cash deposits
- Lawyers and conveyancers: Trust account cash deposits
- Accountants: Cash payments for services or on behalf of clients
Key Takeaway
Threshold Transaction Reports are mandatory for cash transactions of $10,000 or more - no suspicion required. File within 10 business days via AUSTRAC Online. If you suspect structuring, also file an SMR. Remember to keep all records for 7 years.
Read our complete Tranche 2 Guide
Key dates, affected sectors, obligations and how to prepare
Disclaimer: This article is general information only. It is not legal, financial or compliance advice. HeadStart Docs™ provides free compliance documents, not legal services.
We do not guarantee the accuracy of information provided. Obligations may apply depending on your designated services. Always confirm your specific requirements with a qualified adviser.
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