What happens when your client pays cash: threshold transaction reports explained — AML Simple

Physical cash of A$10,000 or more in a property transaction must be reported to AUSTRAC within 10 business days.

This is the Threshold Transaction Report (TTR) — a mandatory reporting obligation that is separate from Suspicious Matter Reports and triggered by a dollar amount, not a judgment call.

Most real estate agencies will trigger this rarely. Cash deposits happen. Trust account cash receipts happen. And the obligation applies the moment physical cash reaches the threshold, whether you encounter it once a year or once a decade.

The fastest way to have TTR procedures covered

Your AML/CTF program must document how your agency handles threshold transaction reports before 1 July 2026.

Sign up to AML Simple — around 2 minutes. Enter your ABN and AML Simple pulls your registered business details from the ABR automatically. Your organisation profile is pre-filled.
Use the AUSTRAC Enrolment Cheat Sheet — around 5 minutes. Open AUSTRAC Connect in one tab, open the Cheat Sheet in another. Every field AUSTRAC needs is pre-filled from your account.
Run the AML/CTF Program Generator — around 15 minutes. The wizard builds your program document consistent with AUSTRAC's Program Starter Kit structure, including your cash transaction monitoring and TTR reporting procedures.

Your program covers both TTRs and Suspicious Matter Reports as part of a single documented workflow.

Prefer to understand the obligation in detail? The rest of this post explains exactly how TTRs work.

What triggers a TTR

A TTR is required when your agency receives or handles physical cash of A$10,000 or more.

Physical cash means banknotes and coins.

These do NOT trigger a TTR:

Bank transfers or electronic fund transfers
Cheques
Credit or debit card payments
BPAY or other electronic payment methods

Only physical currency counts.

The obligation applies whether the payment comes directly to you or goes into your trust account on behalf of a client.

Linked transactions

The threshold also applies to linked transactions — multiple cash payments that together reach A$10,000 and appear to be connected.

If a client pays a A$6,000 cash deposit on Tuesday, then brings in another A$5,000 cash on Thursday for the same property purchase, those transactions are linked. The combined total is A$11,000. A TTR is required.

Your systems need to catch this — tracking cash receipts per client across a transaction, not just treating each payment in isolation.

When to file and what to include

File through AUSTRAC Online within 10 business days of the transaction.

What to include in the report:

The name and details of the person or persons involved
The amount of cash and the currency (AUD or foreign equivalent)
The date of the transaction
The purpose of the transaction
Your agency's details

One report per transaction. If a transaction involves multiple people (for example, two buyers making a joint cash deposit), include details for each person.

The structuring risk

Structuring is when someone deliberately breaks a cash payment into smaller amounts to avoid the A$10,000 threshold.

Examples:

A client pays A$7,500 cash, then returns three days later with another A$8,000 for the same property
Multiple cash deposits of A$9,000 from the same person into your trust account over several days

Structuring is a criminal offence under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (s 142).

It also triggers your Suspicious Matter Report obligation — independently of whether any single cash transaction reaches A$10,000.

You do not need to be certain that structuring is occurring. A reasonable suspicion is enough. The SMR deadline for money laundering concerns is 3 business days from forming that suspicion.

The practical implication: even when no single cash payment reaches the threshold, a pattern of cash payments below A$10,000 from the same person on the same property is the kind of pattern SMR procedures are designed to flag for review.

What your agency needs in place before 1 July 2026

Your AML/CTF program must document your TTR procedures.

That covers:

Clear guidance for staff on what counts as physical cash (banknotes and coins only)
A process for identifying transactions at or approaching A$10,000
A system for tracking linked transactions across the same client or property
A clear filing process and deadline reminder for when the threshold is triggered
Record-keeping for all TTRs filed — retained for 7 years minimum under the AML/CTF Act 2006 (s 107)

In practice, most agencies set an internal alert threshold below A$10,000 — for example, flagging any single cash receipt above A$5,000 — to allow time to check for linked transactions before the 10-day deadline passes.

Should your agency accept large cash payments?

The legislation does not prohibit accepting cash.

But many agencies are adopting policies that limit physical cash — for example, "all payments above A$2,000 must be made by electronic transfer."

A policy like this reduces your TTR obligations, simplifies record-keeping, and removes a category of money laundering risk from your transactions. It is a legitimate business decision with a compliance benefit.

Where such a policy is adopted, documenting it in the AML/CTF program signals a deliberate risk-management choice to AUSTRAC.

TTRs versus SMRs — the key difference

TTRs are objective. A$10,000 physical cash. 10 business days. No judgment required.

SMRs are judgment-based. You file an SMR when you have reasonable grounds to suspect money laundering, terrorism financing, or structuring — regardless of the transaction amount.

The two can overlap. A large cash payment that also looks suspicious needs both a TTR (for the threshold) and an SMR (for the suspicion).

A pattern of small cash payments that looks like structuring needs an SMR, even if no single transaction reaches A$10,000.

AML Simple includes both SMR and TTR procedures in your program document, and keeps your transaction records in one place for the full 7 years required by law.

Start your AML program at AML Simple — the setup takes under 25 minutes.

General information only, not legal or compliance advice. For guidance specific to your agency's circumstances, consult a qualified AML/CTF compliance professional.

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