Writing an SMR: What AUSTRAC Actually Needs From You

When is an SMR actually required?

When you form a suspicion, on reasonable grounds, that a transaction or attempted transaction may involve proceeds of crime, tax evasion, terrorism financing or related conduct. Two words carry all the weight. "Suspicion" is lower than proof — you do not need to know what the crime is, only that the facts do not add up honestly. "Reasonable grounds" means you can articulate why: specific facts, not vibes.

Note also: attempted transactions count. A buyer who walks away the moment you ask about funding can still be reportable conduct. The deal dying does not kill the obligation.

The clock starts when suspicion forms — so date it

You have 3 business days from forming the suspicion, or 24 hours where terrorism financing is involved. The trap is that "when suspicion formed" is a fact you control by documenting it. An undated, drifting unease that hardens over three weeks is a compliance problem; a documented note — "on this date, on these facts, I formed a suspicion" — starts a clean clock.

So build the habit: the moment escalation turns into suspicion, write the date down. That one line protects both the timeline and you.

What a good SMR contains

Who, what, when, and why it smelled wrong. Identify the parties with everything CDD gave you — full names, dates of birth, addresses, entity structures and beneficial owners. Describe the transaction concretely: the property, price, deposit arrangements, how funds were to move. Then the heart of the report: the specific facts that triggered suspicion, in plain chronological English.

"Purchaser stated deposit was from savings on 4 March, then described it as a loan from an associate on 11 March; declined to name the associate" is a good sentence. It is specific, dated, and observable. Ten of those beat any amount of analysis.

What stays out

Speculation about which crime you think occurred — you are reporting suspicion, not charging anyone. Character commentary and adjectives: "dodgy", "shifty" and "clearly laundering" add nothing and age badly. Padding — the analyst does not need the property brochure.

Also resist the urge to soften the facts to be fair to the customer. Fairness is served by accuracy, not by hedging. Report exactly what happened and let the facts be whatever they are.

After lodgement: silence and business as usual

Tipping off is a criminal offence: the customer must never learn, from words or behaviour, that a report was made or is being considered. That includes the well-meaning colleague hinting that "there's some compliance stuff happening". Keep the circle to those who genuinely need to know, and brief them on exactly that point.

The transaction itself proceeds on its commercial merits unless a distinct legal reason stops it. An abrupt, unexplained withdrawal right after lodgement can itself signal that a report exists — behave normally, decide normally, document normally.

The workflow that makes SMRs easy is the one you built earlier

Every hard SMR is hard for the same reason: the facts were never captured when they happened. If your CDD records, screening decisions, conversation notes and escalations already live in one transaction file, an SMR is an assembly job — an hour, not a weekend of inbox archaeology. And the whole trail, report included, is kept for seven years.

That is the honest pitch for a reporting workflow: not that it writes the report for you, but that it means the report was effectively written as the file was built. On Indium the escalation, decision log and record trail sit inside the transaction, so the 3-day clock is an admin task, not a crisis.

One last reframe for the compliance officer staring at their first report: lodging an SMR is not a failure of your program. It is your program working. The agencies that should worry are the ones that never form a suspicion about anything — not because their customers are cleaner, but because nobody is looking. A well-run agency will occasionally see something worth reporting, report it factually and on time, and get on with selling houses.

Keep a skeleton template ready before you need it: party details section, transaction section, chronology of facts, blank. When suspicion forms, you fill in fields instead of confronting a blank page against a deadline. Small preparation, large difference at 4pm on day three.

And read your own report back once, aloud, before lodging. If a stranger could follow the story — who, what, when, why it looked wrong — it is done. If it needs you standing next to it explaining, it isn't yet.