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Compliance
October 4, 20269 min read

How to lodge an SMR in AUSTRAC Online without tipping off

The reporting entity lodges a suspicious matter report in AUSTRAC Online. Not tipping off means you do not tell the client that a suspicion exists or that a report has been made.

Quick answer

How to lodge an SMR with AUSTRAC, at the level a small firm needs, is three principles, and the business lodges, not the software vendor. The fact of the suspicion and the report stays with the people inside the firm who must know, and the client is not told, and is not given a clever explanation that reveals the report. This page does not walk the AUSTRAC Online screens and does not suggest words to use with the client, and FreeAML does not lodge the report. The firm suite is A$0.

People search “how to lodge SMR AUSTRAC” when a two-partner firm has decided a report is required and is looking for a script that keeps the client comfortable. Checked against AUSTRAC’s suspicious matter report guidance on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. What the report is for a new firm is suspicious matter reports in Tranche 2. What you do not say to the client is what not to tell a client. The sector map is /tranche-2.

Lodge inside the firm, say nothing outside it

A suspicious matter report is the reporting entity telling AUSTRAC about a suspicion the law requires it to report, and the lodgement happens in AUSTRAC Online, by the business, under the access the business holds. How to lodge an SMR with AUSTRAC is AUSTRAC’s own instruction once you are inside that system. This page does not repeat the screens, the fields, or a sequence of clicks. A click-path published here would go stale and would pretend to be the regulator’s form.

Tipping off is the other half of the same job, and you do not tell the customer, and you do not tell another person where that disclosure is prohibited, that you have formed a suspicion or that you have lodged or may lodge a report. The safe working rule in a two-partner firm is plain, and the people who must know, know. The client letter, the status email, and the conversation at reception do not mention a report, and this page will not offer wording that hides the report inside a polite excuse. That would be the wrong help, so this page stays at principles only.

  • The reporting entity lodges. A vendor account does not lodge for you. Know who in the firm has AUSTRAC Online access before you need it.
  • Keep the circle small. The compliance officer and the people the program names are told. The rest of the office is not briefed for interest.
  • The client is not informed. Do not confirm a report, deny a report, or hint that one is the reason you are pausing. Ordinary document requests stay ordinary.
  • The internal note stays internal. Record the decision on the matter. Do not paste that note into anything the client receives.

Who knows, and who does not

The filing guide, which is the neighbouring article and not this one, is the SMR filing guide. Use it for structure. Use this page for the rule that the client is not told.

A sorting aid for a small firm. This table does not reproduce AUSTRAC’s suspicious matter guidance.

PersonWhat they may knowWhat you do not do
Compliance officerThat a report is being considered or has been lodgedLeave the decision with no owner
Staff the program namesWhat they need to do their partBrief the whole office
The clientNothing about the suspicion or the reportExplain the pause by referring to AUSTRAC
The software vendorNothing that asks the vendor to lodge or to hide the reportTreat a check result as the SMR

Where the lodgement page stops

This page is the principle that the firm lodges and the client is not told. It is not a screen guide, a script, or a way to delay or conceal a report. FreeAML does not lodge SMRs and does not tell you what to say.

What the client pays

On FreeAML the firm suite is A$0. The firm emails the client a link. Verification is client-pays. On the public list a personal KYC check is A$20 and a company or trust KYB check is A$40. Use KYB when the customer is a company or a trust. An SMR is not a client-pays KYC or KYB check, and the client is not invoiced for the lodgement. Confirm the live amounts on FreeAML pricing. FreeAML does not lodge a suspicious matter report or suggest what to say to the client.

Frequently Asked Questions

The firm lodges. The client is not told.

The firm suite is A$0. The client pays only a KYC or KYB check the program requires. FreeAML does not lodge an SMR.

Open the Tranche 2 guide

Questions: team@freeaml.com.au