Threshold transaction reports: the Tranche 2 cash rule
When A$10,000 in notes and coins triggers a threshold transaction report, when it doesn't, and what AUSTRAC's 14 October update means for your firm.
A threshold transaction report (TTR) tells Australian Transaction Reports and Analysis Centre (AUSTRAC) that your business received or paid A$10,000 or more in physical currency, meaning notes and coins, while providing a designated service. It is not about suspicion. If the cash is handed over and the amount is reached, the report is due, even if the customer is entirely ordinary.
On 14 October 2026, AUSTRAC updated its TTR guidance to make clear when a transaction involves physical currency, with new examples covering mixed payments, bank deposits and bank statements. This page sets out what that means for accountants, lawyers, conveyancers, real estate agents and dealers in precious metals and stones. Your other reporting obligations are covered in AUSTRAC reporting forms.
What the law says
- Trigger
- A$10,000 or more in physical currencyNotes and coins, Australian or foreign, that you receive or pay while providing a designated service. Exactly A$10,000 counts (Act ss 5, 43)
- Not caught
- Bank transfers, cheques, cards, and cash deposited at a bankIf a client deposits cash into your bank account, the bank reports it
- Deadline
- Within 10 business daysAfter the day the cash changes hands (s 43(2)). A civil penalty provision
- Several payments
- Each one is a separate transactionYou don’t add them up, but you monitor for structuring
- Structuring
- A criminal offence (s 142)Up to 5 years’ imprisonment or 300 penalty units, or both. Suspecting it means a suspicious matter report
- Form
- The new TTR formFor every business enrolled after 30 March 2026, which includes Tranche 2 firms
- Where
- AUSTRAC Online
Sources: Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (ss 5, 43, 142); AUSTRAC, Threshold transaction reports Reviewed
Section 43 of the AML/CTF Act applies when a reporting entity provides a designated service to a customer and the provision of the service involves a threshold transaction. Section 5 defines a threshold transaction as a transaction involving the transfer of physical currency where the total physical currency transferred is not less than A$10,000. Physical currency is coin and printed money, Australian or foreign, that is legal tender and customarily used as money in the country that issued it.
Key point
Under Australia's AML/CTF Act, a reporting entity must report a threshold transaction to AUSTRAC within 10 business days after the day the transaction takes place.
Three things follow. The threshold is A$10,000 or more, so exactly A$10,000 counts. Foreign notes count at their Australian dollar value. And the transfer has to happen as part of a designated service, so cash in a part of your practice that provides no designated service is not caught by section 43.
What counts as receiving or paying cash
AUSTRAC's updated guidance says a transaction only involves physical currency if you receive or pay notes or coins. If you don't physically handle them, it is not your threshold transaction.
| Involves physical currency | Does not involve physical currency |
|---|---|
| Notes or coins received or paid over the counter or in person | A deposit into your bank account, unless you are the bank receiving the cash |
| Notes or coins received or paid by mail or courier | Electronic funds transfer, internet banking, BPAY or PayID |
| Refunding a payment in notes or coins | Cheques, however they arrive |
| Paying out balances or other amounts as notes or coins | A bank statement showing cash deposits, used as evidence of funds |
Two of AUSTRAC's examples matter most for Tranche 2. In the first, a customer wants to buy A$15,000 of gold bullion with cash, and the dealer asks them to deposit it into the dealer's bank account instead. The bank receives the notes, so the bank lodges the TTR and the dealer does not. In the second, a real estate agent asks a cash buyer about their source of funds and is shown a bank statement with several cash deposits of A$10,000 or more. The bank that took those deposits reports them. The agent does not, even though the money will go towards the property.
The statement still matters. Large cash deposits are part of what you weigh in the customer's risk rating and source of funds, and if they give you reasonable grounds for suspicion, a suspicious matter report applies instead.
Mixed payments
What counts is the physical currency in the transaction, not its total value. In AUSTRAC's example, a customer receiving A$12,000 asks for A$10,000 in cash and A$2,000 by bank transfer. The A$10,000 cash portion is reportable. The next month, the same customer takes A$9,000 in cash and the rest by transfer, and no TTR is needed. On the same reasoning, for a deposit paid partly in cash and partly by transfer, only the cash part is measured against A$10,000.
When the report is due
When the clock starts: a cash deposit on a sale
AUSTRAC’s example: real estate deposit and settlement
- Day one
A$21,250 cash deposit
The buyer hands the agent notes. This is the threshold transaction.
- Within 10 business days
Lodge the TTR
After the day of the cash payment, in AUSTRAC Online.
The contract, signed a week later, does not move the clock.
- 6 weeks later
Settlement by electronic transfer
Not physical currency, so no TTR.
Sources: AUSTRAC, Threshold transaction reports; Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (s 43(2)) Reviewed
The clock runs from the day the transaction takes place, which is the day the cash changes hands. AUSTRAC's real estate example: a buyer hands the agent A$21,250 in cash as a deposit, signs the contract a week later and pays the balance by electronic transfer six weeks after that. The threshold transaction took place on day one, so the TTR is due within 10 business days of the cash payment. The electronic settlement needs no TTR.
Missing the deadline is a contravention of a civil penalty provision (Act s 43(4)). Reports are lodged in AUSTRAC Online.
Several payments, and structuring
Each physical currency payment is a separate transaction. You don't combine them, even when they come close together or at different locations. In AUSTRAC's jeweller example, a customer pays for a A$20,000 bracelet in A$2,000 cash instalments over a month. No TTR is needed, but the jeweller should consider whether the instalments are a way to avoid one.
Splitting cash to avoid a TTR is called structuring, and it is a criminal offence under section 142 of the Act, with a maximum penalty of 5 years' imprisonment or 300 penalty units, or both. Your obligation is to monitor for it. If you have reasonable grounds to suspect a customer is structuring, you must lodge a suspicious matter report, and if you keep providing the service you must apply enhanced customer due diligence.
Key point
AUSTRAC says that if a reporting entity has reasonable grounds to suspect a customer is splitting cash payments to avoid a threshold transaction report, it must lodge a suspicious matter report.
AUSTRAC's real estate example shows what that looks like at a small firm. A buyer agrees to a A$50,000 deposit and asks to pay it in cash as five payments of A$9,000 and one of A$5,000. Asked why, the buyer becomes irritated and gives no legitimate reason. The agency's manual monitoring flags it, and the agent lodges a suspicious matter report. That report is due within 3 business days of forming the suspicion, or 24 hours if it relates to terrorism financing, and you must not tip the customer off.
What the report must include
Division 2 of Part 9 of the AML/CTF Rules sets out the contents. To the extent it applies and is known to you, a TTR covers:
- your business and the individual completing the report
- the customer, and anyone the customer received the service on behalf of
- for a company or trust, its beneficial owners, the people with primary responsibility for governance, and for a trust its trustee, settlor and beneficiaries, or classes of beneficiary for a trust with more than 10
- anyone acting for the customer, how they are related and their authority to act
- the transaction: when and where, its Australian dollar value, any foreign currency, its purpose if known and the designated service provided
- a description of the data you used to verify the customer's identity.
AUSTRAC asks you not to include tax file numbers, which the Act doesn't authorise you to disclose, and not to fill optional fields with words like "unknown". If information is covered by legal professional privilege, you submit an LPP form with the TTR.
Which form to use
Section 12-4 of the Rules lets businesses that were already enrolled on 30 March 2026 keep using the old form until 30 March 2029, unless AUSTRAC sets an earlier date. AUSTRAC says anyone who enrolled after 30 March 2026 must use the new form. Enrolment for Tranche 2 opened on 31 March 2026, so every newly regulated firm is on the new form.
When the rule doesn't apply
The Act switches TTRs off in four situations: a service provided through a permanent establishment in a foreign country (other than by a remittance network provider), an Australian financial services licensee arranging for a person to receive a designated service, an authorised deposit-taking institution, such as a bank, providing a service to another, and transactions between holders of exchange settlement accounts using those accounts (s 44(5) to (8)). None of these is likely to apply to a small Tranche 2 firm.
What StackGo does, and where the rest happens
StackGo doesn't take payments, handle cash or lodge reports. TTRs and suspicious matter reports are lodged by your business in AUSTRAC Online, and monitoring for cash and structuring sits in your anti-money laundering and counter-terrorism financing (AML/CTF) program.
What a TTR asks for about the people involved is the same information your customer due diligence already collects. With StackGo, the client completes an Intake form, their identity is checked and, for a company or trust, its beneficial owners are established (Verify), and the result is written back to the client record. Your team records a High, Medium or Low rating and the decision against the client (Assess), so a cash deposit that changes the picture can be reflected in the rating on the same file.
To see a client check run end to end, book a demo.
Frequently asked questions
Is it 10 days or 10 business days?
10 business days after the day of the transaction, under section 43(2) of the Act. AUSTRAC's 30 September 2026 article How to get your reporting right shortens this to "10 days". Follow the Act.
A client paid A$10,000 into our trust account in cash at their bank branch. Do we report it?
No. The bank received the notes, so the bank lodges the TTR. You didn't receive physical currency.
A buyer's bank statement shows large cash deposits. Do we lodge a TTR?
No. AUSTRAC's example says the bank that received the deposits reports them. Consider the deposits in your source of funds and risk assessment, and lodge a suspicious matter report if you form a suspicion on reasonable grounds.
Is exactly A$10,000 reportable?
Yes. The Act's threshold is A$10,000 or more.
Do card payments or cheques count?
No. AUSTRAC says electronic transfers, cheques and card payments don't trigger a TTR, whatever the amount.
Sources
Checked on 28 October 2026.
- Anti-Money Laundering and Counter-Terrorism Financing Act 2006, sections 5, 43, 44 and 142 (compilation of 1 October 2026)
- Anti-Money Laundering and Counter-Terrorism Financing Rules 2025, Division 2 of Part 9 and section 12-4 (compilation of 31 March 2026)
- AUSTRAC: Threshold transaction reports (updated 14 October 2026)
- AUSTRAC: Latest guidance updates (entry of 14 October 2026)
- AUSTRAC: Suspicious matter reports (updated 9 September 2026)
- AUSTRAC: How to get your reporting right (30 September 2026)