Structuring cash under $10,000: still an SMR issue

People search “structuring cash real estate SMR” when a suburban agency sees more than one cash payment on a sale, each sitting just under the threshold, and treats the pattern as clean. Checked against AUSTRAC’s risks and indicators page on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. The threshold report itself is the threshold transaction report. The suspicion report is the suspicious matter report for Tranche 2. The sector map is /tranche-2.

Under the line is not the end of the question

A threshold report is about a transaction that meets the threshold. A suspicious matter report is about a suspicion, including a suspicion that someone is trying to stay out of a threshold report. AUSTRAC’s indicators page is the frame. This page does not reproduce it and does not explain how to divide a payment.

The suburban agency writes what it saw: more than one cash amount, close together, each under the line, on the same sale. That note goes to the person who decides suspicion. Staff do not answer a buyer who asks what amount avoids a report. The question is itself a reason to fetch that person.

• Keep the two reports apart. One is a threshold report. The other is a suspicion report. Being under the line speaks to the first. It does not close the second.
• Record the pattern, not a recipe. Dates, amounts as you received them, and who paid. Do not write a worked example of how the amounts could have been arranged.
• Do not quote a safe figure. If a buyer asks what cash level avoids a report, you do not answer with a number. You stop and escalate.
• Do not describe the worry to the buyer. Telling them why the pattern matters can become tipping off. Say you need the named person. Do not coach the next payment.

What the desk notices

The rows are observations. They are not instructions. Nothing here is a way to receive cash.

Where the structuring page stops

This page is the suspicion question when cash sits under the line. It is not the threshold report and it is not the lodging guide for a suspicion. Those are the threshold transaction report and the suspicious matter report for Tranche 2.

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. Noticing a cash pattern is not a check, and the firm suite does not include a decision about a suspicious matter report. Confirm the live amounts on FreeAML pricing. FreeAML does not decide you have a suspicion or describe how to split a cash payment.

Frequently Asked Questions