What Is a Suspicious Matter Report? A Plain English Guide for Venue Staff

What Is a Suspicious Matter Report?

A Suspicious Matter Report (SMR) is a report you file with AUSTRAC when you suspect — or have reasonable grounds to suspect — that a person or transaction may be related to:

• Money laundering — disguising the proceeds of crime as legitimate
• Terrorism financing — providing funds to support terrorist activities
• Tax evasion or other serious criminal activity
• Proceeds of crime — the money or assets came from illegal activity

When Should You File an SMR?

You must file an SMR when you form a suspicion — not certainty. You don’t need to prove anything. If something doesn’t feel right, that’s enough to trigger a report.

Common triggers in pubs and clubs:

1. Unusual payout patterns — a patron requesting multiple payouts just under the threshold on the same day
2. Bill-stuffing — a patron feeding large amounts of cash into a machine with minimal gameplay, then cashing out
3. Nervous or evasive behaviour — a patron who avoids ID checks, gives inconsistent information, or seems anxious
4. Third-party collections — someone collecting a payout on behalf of another person
5. Unusual hours — large transactions at opening or just before closing
6. Known criminal associations — a patron you know or suspect to be involved in criminal activity
7. Structuring — deliberately splitting transactions to avoid detection thresholds
8. Reluctance to provide ID — when identification is required and the patron resists or leaves

How Quickly Do You Need to File?

The clock starts when the suspicion is formed, not when the transaction occurs. If a staff member notices something suspicious on Monday but doesn’t report it internally until Wednesday, the 3-day clock started on Monday.

Who Can File an SMR?

Only authorised personnel should file SMRs with AUSTRAC. In most pubs and clubs, this is the:

• Venue Compliance Officer (VCO)
• Venue Manager (VM)
• Group Compliance Officer (GCO) for multi-venue groups

However, any staff member should be trained to recognise and escalate suspicious activity. The process should be:

1. Staff member notices something suspicious
2. Staff member escalates to the compliance officer or venue manager immediately
3. Compliance officer assesses the situation and determines whether to file
4. Compliance officer files the SMR with AUSTRAC within the required timeframe

What Happens After You File?

The Tipping-Off Offence — s123

Penalties for tipping off:

• Up to 2 years imprisonment
• Criminal conviction on your personal record
• This applies to individual staff members, not just the venue

This is why SMR information should be restricted to the compliance officer and venue manager on a strict need-to-know basis.

What If You Don’t File?

Failing to file an SMR when you had reasonable grounds to suspect suspicious activity is a breach of the AML/CTF Act. Consequences include:

• Civil penalties of up to $33 million per contravention for corporations
• Remedial directions from AUSTRAC
• Reputational damage — AUSTRAC enforcement actions are public
• If the unreported activity turns out to be serious crime, your venue could face additional scrutiny

Quick Reference: SMR Checklist

• Trust your instincts — if something feels wrong, escalate it
• Document what you observed — who, what, when, where, why it’s suspicious
• Escalate immediately to your compliance officer or venue manager
• Do not tip off the patron or discuss the SMR with unnecessary staff
• File within 3 business days (24 hours for terrorism financing)
• Keep records of the SMR and your decision-making process for 7 years
• Continue providing normal service unless directed otherwise — don’t refuse service just because you’re filing an SMR