The trigger for a threshold transaction report (TTR) is a single transaction involving physical currency of $10,000 or more. Physical currency means notes and coins, so the obligation runs on cash itself, not on bank transfers, cheques or card payments.
The obligation sits in s43 of the AML/CTF Act 2006 (Cth) (the Act), and it lands on you if you are a reporting entity: a person or business that provides a designated service, meaning a service the Act lists, like assisting in a conveyance or creating or restructuring a company or trust. Table 6 of the Act sets out those professional services, with real estate agency work in Table 5 and precious metals and stones in Table 2. The sectors in scope since 1 July 2026 include accountants, legal practitioners, conveyancers, real estate agents, dealers in precious metals and stones, and trust and company service providers. Capture follows the service, not the firm: a practice that assists with a conveyance once a quarter is a reporting entity to that extent, and being small does not move the threshold.
Most firms in that list meet a threshold transaction a handful of times a year, which is exactly why the deadline gets missed: the process sits unused for months, then has to work under pressure. Once the transaction happens, the clock is ten business days. Section 43(4) sets the deadline, and it runs from the transaction itself, not from when the cash is reconciled, counted or banked. Business days exclude weekends and public holidays, so ten business days is usually closer to two calendar weeks.
Enrolment with AUSTRAC opened on 31 March 2026, and the reporting obligation applies to transactions from 1 July 2026. Nothing before that date needs a TTR.
The $10,000 threshold is per transaction
The threshold is a per-transaction test. One dealing that involves physical currency of $10,000 or more is a threshold transaction, and that single dealing produces one TTR. In this context a transaction is a single exchange: cash handed over at one time, in one dealing. A day full of smaller cash receipts does not become one report by adding up, and one large payment does not become several by splitting the invoice. The trigger does not care which service produced the cash: it applies whether the $10,000 is a deposit on a property, payment for a precious metal, or fees received in cash.
Cash is the notes and coins of any country. It does not include bank transfers, cheques, card payments or electronic money, so no matter how large, a transfer never triggers a TTR. The rule exists because physical cash moves without a trail; threshold reporting is how that trail gets rebuilt.
| Situation | What you file | Deadline |
|---|---|---|
| A single transaction in physical currency of $10,000 or more | Threshold transaction report (TTR) | 10 business days from the transaction (s43(2)) |
| A cash transaction below $10,000 | No TTR; retain the record | No reporting deadline; keep the record for seven years |
| Foreign currency worth $10,000 or more | TTR at the equivalent Australian dollar value | 10 business days from the transaction (s43(2)) |
The first row is the core of s43: cash of $10,000 or more, reported on time. The second row is the quiet one. A sub-threshold transaction produces no report, but the record still matters, and retention runs for seven years. The record must stay retrievable for the whole period, which rules out storage no one can access after the person who set it up leaves. The record-keeping page sets out what you keep and from when the period runs.
The third row carries a flag. Foreign currency counts at its equivalent value, so a payment in another currency can still cross $10,000. The mechanics of conversion, including which rate applies and on what day, are not yet pinned down, which is covered below. Until the conversion mechanics are settled, keep the rate you used and the date you applied it, so the report is reproducible.
Two separate transactions under the threshold are two sub-threshold transactions, not one report. Whether AUSTRAC would treat transactions that are really a single arrangement as one transaction is the aggregation question, also covered below.
What goes into the report itself is fixed by the lodgement process: the transaction, the parties, the amount and the cash involved, in the form AUSTRAC provides. The report is lodged by you, not by the customer. Filing it is your obligation even where the cash belongs to someone else, and the filed report is itself a record, kept for seven years like everything else in the file. Lateness is measured from the same s43(2) clock, so a report lodged after the ten business days is late regardless of when it was drafted.
When a threshold transaction happens, the practical question is who notices. If payments are recorded in a book that only the accounts team sees at month end, the ten business days can be gone before anyone classifies the transaction. The trigger belongs at the point of payment, in the system that records the money.
What catches people out
Three things separate firms that file on time from firms that find out about s43 from a compliance letter.
The threshold is per transaction, and structuring is an offence: a $24,000 cash payment accepted as $9,500 twice does not dodge the obligation. Structuring, deliberately arranging a transaction to stay under the reporting threshold, is itself an offence. Two payments of $9,500 on consecutive days against the same invoice are one invoice and one transaction in substance, and the same logic applies to three payments of $6,700 or a series of withdrawals shaped to stay under the limit. If AUSTRAC sees a pattern of cash payments sitting just under the threshold, the arrangement can be treated as a single transaction. The consequence is a separate offence, on top of whatever the underlying transaction involves. A client who asks for a payment to be broken up is asking you to take part in it.
Foreign currency counts at the equivalent value: a cash payment in euro or US dollars is measured in Australian dollars at the exchange rate. Look only at the currency you received and you can miss the trigger entirely. The consequence is a TTR that never gets filed, and an unreported threshold transaction is a breach of s43.
A TTR is not an SMR: a suspicious matter report (SMR) is filed because you suspect a transaction is suspicious, whatever its size, and it runs on its own clock: three business days from when the suspicion forms, under s41(2). A TTR runs on the amount and allows ten business days under s43(2). The consequence of running them together is filing one and believing you are done. A $15,000 cash transaction you also find suspicious needs both reports, each on its own deadline. The suspicious matter reports page covers the SMR clock in detail.
What is still unsettled
Two things in this area are not yet pinned down by the regulator. The first is aggregation: how a series of cash transactions that individually sit under the threshold, but together cross it, will be treated. The second is foreign currency: the conversion mechanics, including the rate and the date it applies. Both questions turn up in real transactions: a buyer who pays a deposit in three cash instalments across a week, or a seller who quotes in US dollars, will run into them in the first year. The AML/CTF Rules (2025) may settle either. Until a position is published, treat both as open questions in your risk assessment, and document the rationale for treating a series of payments as separate transactions so a reviewer can see the decision was made rather than missed.
Where to start
Three steps do most of the work in the first month:
- Know your trigger: list the services you offer that can take physical currency of $10,000 or more in one dealing, so the report is prompted at the counter, not discovered at month end. For most firms the list is short: a handful of services, maybe one.
- Set the clock from the transaction: count ten business days from the dealing itself under s43(2), and record the trigger date in the file so the deadline is provable.
- Keep the record for seven years: retain the report, the transaction details and the decision, and treat retention as part of the same workflow, not a separate afterthought. None of the three takes more than an afternoon, and all three are the difference between a missed report and a provable one.
How duely handles this
The threshold in duely is physical-currency-correct: it counts cash of AUD $10,000 or more, rather than treating every large transaction as reportable. Cross-border movement reporting is a firm-level toggle, since it does not apply to every firm, and deadline watchdogs run daily against the draft register. IFTI is supported for completeness, though it rarely attaches to a Tranche 2 firm.