How to Write a Suspicious Matter Report — Step by Step
A well-written SMR can support a major criminal investigation. A poorly written one is useless to AUSTRAC and leaves your venue exposed. This is the practical, step-by-step guide to writing SMRs that meet the statutory standard and produce real intelligence value.
Why SMR Quality Matters
AUSTRAC receives hundreds of thousands of SMRs each year. The ones that have operational value — that lead to investigations, that connect dots for law enforcement, that support intelligence work — share specific characteristics. The ones that do not share different characteristics.
For your venue, SMR quality matters for two reasons. First, AUSTRAC assesses the quality of SMRs in compliance reviews. A venue that files vague, templated, or incomplete SMRs may be found non-compliant even if the raw filing count looks adequate. Second, a well-documented SMR — with a clear narrative, specific evidence, and a documented decision trail — is your venue’s defence if the underlying matter is later scrutinised.
Good SMRs are not long. They are specific, structured, and grounded in the actual facts your venue observed.
Before You Start Writing
Most SMR failures begin before a word is written. Before drafting, confirm:
Pre-Write Checklist
- The suspicion has been reasonably formed — not speculation, not hunch, but grounded in specific observations
- The grounds are written down in your internal escalation record
- The compliance officer has reviewed the escalation and confirmed the SMR should be filed
- Source records (transaction logs, CCTV references, identification records) are identified and retrievable
- The statutory deadline is understood — 3 business days for most matters, 24 hours for terrorism-related
- Tipping-off controls are in place — only the compliance officer and senior management know
If any of these elements is missing, pause and address it before drafting. A poorly scaffolded SMR process produces poorly scaffolded SMRs.
Step 1 — Identify the Subject
The AUSTRAC Online form begins with the subject of the report: the person or persons your venue suspects.
What to Capture
- Full legal name (as recorded during CDD, if identification was performed)
- Date of birth
- Residential address
- Identification document details (type, number, expiry)
- Any known aliases or alternative names observed
- Physical description if no identification was performed
- Associated persons (third parties involved, family members present, known associates)
If the patron was never identified — for example, if the suspicious activity occurred below your CDD threshold — capture as much identifying information as the venue holds: physical description, CCTV time-stamps that show the patron clearly, vehicle registration if observed in the car park, membership number if applicable.
Do not withhold an SMR because the patron could not be fully identified. AUSTRAC’s systems connect SMRs across venues and across sightings. A patron unidentified at one venue may be identified at another, and the combined record becomes the intelligence picture. Your contribution is the observation, not necessarily the identification.
Step 2 — Describe the Transaction(s)
Every SMR relates to one or more designated services your venue provided (or attempted to provide). Be specific about each:
- Date and time of the transaction
- Amount paid out (or attempted)
- Method of payment (cash, EFT, cheque)
- Machine identifier or gaming session reference
- Staff member who processed the transaction
- Whether identification was triggered and performed
- Any associated transactions in the same session or same day
If the SMR relates to a pattern (structuring, bill-stuffing, repeated visits), list each transaction in chronological order with the relevant details.
Step 3 — State the Suspicion
The heart of an SMR is the statement of suspicion. This is what your venue specifically suspects may be happening. It should be concise — one to three sentences — and should name the suspected criminal activity category.
Strong Statement Examples
Example: Structuring
The reporting entity suspects the patron is structuring gaming machine payouts to avoid customer identification triggers. Between 12 and 14 April 2026, the patron received four payouts of between $4,600 and $4,900, each immediately below the venue’s $5,000 identification threshold.
Example: Bill-Stuffing
The reporting entity suspects the patron is using gaming machines to convert cash into venue-issued payouts in a manner inconsistent with genuine gaming. The patron inserted $8,700 across two machines, played fewer than 40 spins, and requested payouts totalling $8,300.
Example: Third-Party Collection
The reporting entity suspects that an unidentified third party is collecting gaming machine payouts on behalf of unknown principals, potentially to disguise the beneficial ownership of the funds. The same individual has collected payouts linked to three different patrons on separate occasions over the past 14 days.
“The patron was acting suspiciously” is not a statement of suspicion. It is a conclusion without content. State what your venue suspects specifically (money laundering, structuring, proceeds of crime) and why.
Step 4 — Explain the Grounds
The grounds section is where you describe the facts that led to your suspicion. It is the most important section — AUSTRAC uses it to assess whether the suspicion was reasonable, and investigators use it to understand what happened.
Structure the Grounds
A good grounds section has three components:
- What was observed — the factual events your staff witnessed
- What is unusual about it — how the observed behaviour departs from normal patron activity
- What the venue infers — the conclusion your venue drew and why
Good Example
On 13 April 2026 at 22:47, the patron approached the gaming floor service desk and requested a payout of $4,850 from machine 47. The staff member processing the payout recognised the patron from a $4,900 payout earlier that afternoon at 15:12, recorded in the venue’s transaction log under reference TR-240413-1248.
Within the preceding 72 hours, the patron had received three further payouts of $4,700, $4,650, and $4,800, each from different machines, each immediately below the venue’s $5,000 customer identification threshold, and each sufficiently below to suggest the threshold was being actively managed. No single payout across this period reached $5,000. The cumulative total over 72 hours is $23,900.
The patron is not a member and has been observed at the venue only within this 72-hour window. When the staff member at the 22:47 payout enquired informally about the patron’s gaming plans, the patron indicated they were “just about done for the week” and did not return.
The reporting entity considers the pattern to be inconsistent with ordinary recreational gaming and consistent with structuring as defined in AUSTRAC guidance. The suspicion is that the patron is deliberately managing payout amounts to remain below the identification threshold.
Notice what this example does: it is specific, it references actual records, it names staff members (in internal drafts — AUSTRAC Online submission may use generic references), it quantifies the activity, it explains why the pattern is unusual, and it draws a reasoned inference.
Step 5 — Include Any Other Relevant Information
The SMR form includes space for additional information. Use it. AUSTRAC intelligence analysts read these sections — context they do not have otherwise is genuinely valuable.
What to Include
- Whether the patron has been associated with prior SMRs from your venue
- Whether your venue has observed patterns involving this patron at other related venues (if known)
- Whether law enforcement has previously enquired about the patron
- Whether the patron has ongoing self-exclusion or barring status in other jurisdictions
- Any external information the venue considers relevant (media reports, member complaints, associations observed)
Keep this section factual. It is an information-sharing section, not a speculation section.
Step 6 — Review Before Submission
Before submitting the SMR, have the compliance officer review the full draft against the following:
- Factual accuracy — every transaction detail, every time, every amount matches the underlying records
- Specificity — vague or generic phrases are replaced with concrete observations
- Inference chain — the conclusion follows from the observations without speculative leaps
- Privacy discipline — the SMR does not reveal to the patron (or anyone who might tell them) that the report exists
- Completeness — all required form fields are populated
- Tone — professional, factual, not judgmental
A second reviewer — another senior person on the compliance team — adds value. They will catch errors the drafter has gone blind to.
Step 7 — Submit and Record
Submit the SMR through AUSTRAC Online. Record the AUSTRAC reference number in your internal SMR log. Save an internal copy of the submitted text for the seven-year record.
Post-Submission Records
- AUSTRAC reference number
- Date and time of submission
- Staff member who submitted
- Full text of the submitted SMR
- All source records referenced (transaction logs, CCTV, identification records)
- The internal escalation record that preceded the filing
- Any subsequent correspondence with AUSTRAC or law enforcement under section 43
Once an SMR is filed, the tipping-off obligations under section 123 do not expire. Years later, if the patron or anyone connected to the patron asks about past transactions, the SMR’s existence cannot be disclosed. Access to SMR records must be permanently restricted.
SMR Templates and the Risk of Templating
Some venues use SMR templates to speed up drafting. Templates can help with structure but become a problem when they drive content. AUSTRAC has flagged “copy-paste SMRs” as a quality concern — reports that read like a template lightly customised lose analytical value.
A better approach: templated structure, bespoke content. The form headings stay the same across SMRs; the narrative in each section is written fresh against the specific facts of the matter.
Where ComplyIQ Fits
ComplyIQ’s SMR workflow captures the internal escalation (staff flag, compliance officer assessment, decision rationale), links source records (transactions, CCTV references, identification) directly to the SMR draft, enforces access controls to prevent tipping-off, and retains the full SMR trail for seven years. The compliance officer drafts in ComplyIQ with every supporting record already linked, reviews, then submits to AUSTRAC Online with a reference number captured back to the ComplyIQ record.
For the full SMR picture, see our Suspicious Matter Reports — The Definitive Guide for Gaming Venues.
Better SMRs. Faster. Defensible.
ComplyIQ turns SMR filing into a structured workflow with source records linked, access controlled, decision trail documented, and tipping-off controls enforced. Your compliance officer drafts once, reviews, files — and the seven-year record is complete by default. One platform for AUSTRAC and state gaming obligations. Support from people who know pubs and clubs.