How to Write an Effective Suspicious Matter Report for AUSTRAC
How pubs, clubs and gaming venues can write clear, factual and useful grounds for suspicion supported by chronology, transaction details and relevant patron context.
A Suspicious Matter Report should do more than record that a gaming venue considered activity suspicious.
It should help AUSTRAC understand what happened, who was involved, why the activity raised concern and what information led the venue to form its suspicion.
AUSTRAC updated its Suspicious Matter Reporting Reference Guide in March 2026 with stronger guidance on writing clear, concise and factual grounds for suspicion. The guidance emphasises logical structure, simple language and enough transaction and customer detail to make the activity understandable.
For pubs, clubs and gaming venues, this means good SMR writing starts with the quality of the information gathered before the report is drafted.
For the complete reporting framework, see our guide to Suspicious Matter Reports for pubs, clubs and gaming venues.
It is the report that communicates the relevant facts, suspicious activity and grounds for suspicion clearly enough for someone unfamiliar with the matter to understand what happened.
What Makes a Good Suspicious Matter Report?
An effective SMR should allow someone unfamiliar with the patron or venue to understand the suspicious activity without having to reconstruct the story themselves.
Strong grounds for suspicion should be
- Clear
- Concise
- Factual
- Logically structured
- Supported by relevant details
- Specific about the suspicious activity
Poor reports leave the reader to work out what may have happened. Stronger reports explain the activity directly and provide enough context to understand why it matters.
Start With the Grounds for Suspicion
The most important part of the report is the explanation of why the venue became suspicious.
Weak
“The patron conducted unusual transactions and their behaviour was suspicious.”
This states a conclusion but gives AUSTRAC very little information about what actually occurred.
Stronger
Explain the relevant visits, transaction activity, gaming behaviour, staff observations and previous patterns that caused the venue to become concerned.
The reader can then understand how the suspicion developed.
For more detail on when the available information becomes sufficient to create a reporting obligation, see When Is a Suspicious Matter Report Required?
Separate Facts From Assumptions
An SMR should distinguish clearly between what the venue knows and what it has concluded from those facts.
Facts
- The patron redeemed $8,700 after limited gaming activity.
- The patron completed similar activity on three previous visits.
- A staff member recorded that the patron asked whether transactions below a particular amount were reported.
Assessment
Taken together, the venue considered the pattern potentially consistent with an attempt to disguise the origin or movement of funds.
The purpose of the SMR is to explain why reasonable grounds for suspicion exist, supported by the facts available to the venue.
Build the SMR Around a Clear Chronology
Chronology is particularly useful where suspicious activity develops across multiple visits, transactions or staff interactions.
A gaming venue may need to bring together information from different shifts, several transactions, repeated visits, previous compliance reviews and enhanced CDD enquiries.
- Initial activity
What first attracted attention? - Subsequent activity
What happened after the initial event? - Internal review
What additional patron or transaction information did the venue examine? - Customer enquiries
What was asked and what information was provided? - Reason for suspicion
Why did the combined information create reasonable grounds for suspicion?
A chronological explanation is usually more useful than listing disconnected transactions without showing how they relate to each other.
Include Specific Transaction Details
Where transactions form part of the suspicion, specificity matters.
Relevant details can include
- Dates
- Times
- Transaction amounts
- Cash amounts
- Payout values
- Relevant gaming instruments
- Venue locations
- Transaction references
- Related parties
- Relevant previous activity
Instead of writing “several large transactions”, provide the relevant amounts, dates and surrounding activity.
The objective is to give AUSTRAC the facts needed to understand the suspicious pattern.
Explain Why the Activity Was Unusual
Transaction data alone may not explain why the venue formed a suspicion.
The SMR should provide enough context to show what made the activity unusual.
Relevant context may include
- Behaviour inconsistent with previous patron activity
- Significant cash movement with minimal gaming
- Repeated patterns across visits
- Inconsistent explanations
- Attempts to avoid identification or compliance processes
- Unexplained third-party involvement
- Activity inconsistent with known customer information
- Information discovered through enhanced CDD
Include Relevant Staff Observations
Frontline observations can provide important context where they relate directly to the suspicious activity.
Useful observations may include
- Questions asked by the patron
- Statements made during the transaction
- Attempts to avoid particular controls
- Explanations that changed during the interaction
- Behaviour associated with the relevant transactions
Avoid
“The patron was obviously laundering money.”
Record the Observation
“The patron asked the gaming attendant whether payouts below a particular amount were reported and subsequently changed the requested transaction amount.”
The second version gives AUSTRAC observable information rather than an unsupported conclusion.
Explain What the Venue Did Next
Where relevant, the SMR should describe the follow-up work that helped the venue move from an initial concern to reasonable grounds for suspicion.
Follow-up may include
- Reviewing previous transactions
- Checking customer information
- Reviewing staff observations
- Conducting enhanced CDD
- Requesting additional information
- Escalating the matter internally
- Identifying related previous SMRs
Relevant follow-up helps connect the original activity with the information that ultimately supported the reporting decision.
Reference Previous Related SMRs Where Relevant
Suspicious behaviour can continue after an earlier report.
If a customer later conducts further activity that creates a new suspicion on reasonable grounds, a separate SMR may be required. Relevant previous SMR reference numbers should be included where appropriate.
Why previous reporting history matters
- It can help connect related activity
- It provides context for later suspicious behaviour
- It can help AUSTRAC connect related intelligence
- It prevents relevant history from being considered in isolation
Appropriately authorised compliance personnel may need the reporting history when assessing new matters, while confidentiality and tipping off obligations still need to be managed carefully.
Avoid Vague or Generic SMR Language
Expressions such as these provide little useful information on their own:
- “Suspicious activity occurred”
- “The transaction seemed unusual”
- “Possible money laundering”
They describe the conclusion without explaining the grounds.
Instead, explain
- What happened
- What made it unusual
- What information was considered
- What pattern emerged
- Why that information resulted in suspicion
Keep the Formatting Simple
Good SMR writing is not about making the report visually dramatic.
AUSTRAC’s updated guidance recommends simple language and logical structure. It also discourages writing grounds for suspicion entirely in capital letters because this can reduce readability and interfere with analytical tools.
Avoid
- Entire sections in capital letters
- Unnecessary jargon
- Dense, difficult paragraphs
- Overcomplicated descriptions
Prefer
- Normal sentence case
- Simple language
- Readable paragraphs
- Logical headings and structure
The structure should make the suspicious activity easier to understand, not harder.
A Practical Suspicious Matter Report Example for a Gaming Venue
The following is an illustrative example only. Whether an SMR is required and what information should be included will depend on the circumstances.
Concern
Repeated high-value cash insertion followed by minimal gaming activity and rapid redemption.
Activity Identified
Between 2 August and 14 August, the patron attended the venue on four occasions.
During those visits, staff records show the patron inserted significant amounts of cash into electronic gaming machines, completed limited gaming activity and redeemed most of the value shortly afterwards.
On 9 August, a gaming attendant recorded that the patron asked whether the venue reported large payouts to government agencies.
Review Conducted
Compliance reviewed the patron’s recent transaction history and identified similar activity during the previous month.
The patron was asked about the source and purpose of the funds as part of the venue’s review process. The explanation provided was inconsistent with information previously supplied by the patron.
Grounds for Suspicion
The combination of repeated cash activity, limited gaming, rapid redemption, questions about reporting and inconsistent information led the venue to form reasonable grounds for suspicion regarding the movement of funds through gaming activity.
It identifies the activity, provides chronology, explains the review and connects the relevant facts with the resulting suspicion. It does not simply state that the patron “looked suspicious”.
What Should Be Checked Before Submitting an SMR?
Before submission, the person responsible should be able to answer each of the following questions from the report itself.
- Who is involved?
- What happened?
- When did it happen?
- Where did it happen?
- What transactions are relevant?
- What behaviour or information raised concern?
- What additional review was conducted?
- Why did the venue form the suspicion?
- Are previous related SMRs relevant?
Good SMR Writing Starts Before the Report Is Written
One of the biggest mistakes venues can make is treating SMR quality purely as a writing problem.
If staff observations are incomplete, transaction information is fragmented and compliance decisions are poorly documented, even an experienced compliance professional may struggle to prepare a strong report.
- Observe
Identify the relevant activity or behaviour. - Record
Capture facts, transactions and frontline observations. - Review
Bring together relevant patron and transaction information. - Assess
Determine whether reasonable grounds for suspicion exist. - Report
Communicate the relevant facts and grounds clearly to AUSTRAC.
Where ComplyIQ Fits
Preparing a high-quality SMR becomes much easier when the underlying information is already connected.
ComplyIQ helps gaming venues bring patron information, transaction activity, staff observations and compliance review into a more controlled workflow.
This gives the person preparing the SMR a clearer record of
- What activity occurred
- When it occurred
- What staff observed
- What supporting information was reviewed
- How the matter was assessed
- Why the reporting decision was reached
It is to ensure the compliance professional responsible for reporting has the information needed to prepare a clear, accurate and defensible SMR.
Related Reading on Suspicious Matter Reporting
FAQs About Writing Suspicious Matter Reports
What should be included in the grounds for suspicion?
The grounds for suspicion should explain the relevant activity, transactions, customer information and other facts that caused the reporting entity to form reasonable grounds for suspicion. The description should be clear, concise and factual.
Should an SMR include exact transaction amounts?
Where transaction amounts are relevant to the suspicion, specific figures are more useful than vague descriptions such as “large transactions”.
Can staff observations be included in an SMR?
Yes, where they are relevant. Statements, questions or behaviour observed by staff can provide important context when described factually.
Is there a Suspicious Matter Report example?
AUSTRAC’s SMR reference guidance includes examples of stronger and weaker reporting. Examples should be used to understand reporting principles rather than copied as templates because each suspicious matter depends on its own facts.
Should previous SMRs be referenced?
Where a new suspicious matter relates to previous reports about the same customer or activity, relevant previous SMR reference numbers should be included where appropriate.
Build Better Suspicious Matter Reporting Workflows
ComplyIQ helps gaming venues connect patron information, transaction activity, staff observations and compliance decisions so the people responsible for reporting can work from a clearer and more defensible record.
Disclaimer: This article provides general information only and does not constitute legal advice. The information included in an SMR and the grounds for suspicion will depend on the circumstances of each matter. Reporting entities should refer to current AUSTRAC guidance and applicable AML/CTF legislation when preparing Suspicious Matter Reports.