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Compliance
October 4, 20269 min read

SMR is lodged in AUSTRAC Online, not a homemade PDF

A suspicious matter report form is the lodgement in AUSTRAC Online. A PDF you design, or a letter you save to the file, is not the report.

Quick answer

Lodge in AUSTRAC Online. Keep any worksheet as your own notes before you lodge, and label it as notes. Do not email a PDF to the client, and do not treat a saved letter as filed. The firm decides whether the matter is reportable, and FreeAML does not lodge it.

People search “suspicious matter report form” when a two-partner firm has drafted a PDF letter and is about to call that letter the report. Checked against AUSTRAC's suspicious matter reports page on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. The filing principles, without a script, are the SMR filing guide. What the report is for under Tranche 2 is the suspicious matter report page. The sector map is /tranche-2.

The channel is the report

Firms ask for a suspicious matter report form because other regulators still take a PDF. AUSTRAC's suspicious matter report is lodged in AUSTRAC Online. A homemade form can help you gather your own facts beforehand. Once you treat that form as the thing you filed, you have a note and no lodgement.

Do not send the note to the customer to check the wording. That is disclosure of a report, which is the tipping-off limit. This page does not describe a softer way to do it.

  • Lodge where the report lives. AUSTRAC Online is the channel. A letter on the letterhead is not a second channel.
  • Label internal notes as notes. A worksheet can list facts you already hold. Mark it so nobody later thinks it was submitted.
  • Keep the client off the draft. You do not ask the customer to approve, correct, or preview a report.
  • The decision stays in the firm. Software that verifies a customer does not decide suspicion and does not submit the report.

Notes, PDF, and lodgement

Put the three objects on the file as three objects. The compliance officer should be able to point at the AUSTRAC Online record separately from anything saved as a PDF. If the only object is the PDF, the report has not been lodged.

What is sitting on the file. This table does not reproduce AUSTRAC's suspicious matter report process.

ObjectWhat it isWhat it is not
AUSTRAC Online lodgementThe reportOptional once a PDF exists
Internal worksheetYour notes before you lodgeA suspicious matter report form
PDF on the fileA copy of your thinkingEvidence you lodged
Email to the clientA disclosure you do not makeA way to confirm the report

Where the form question stops

This page is the channel. It is not a script for what to write, and it is not a promise about timing or penalties. Filing principles are on the SMR filing guide.

A redacted training example is a different use. Do not turn this page into sample wording.

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. A worksheet is not a product fee, and lodgement is not something the client pays FreeAML to perform. Confirm the live amounts on FreeAML pricing. FreeAML does not lodge the report, provide a suspicious matter report form, or decide that your PDF was filed.

Frequently Asked Questions

The channel is AUSTRAC Online. The program says when you use it.

The firm suite is A$0. The client pays verification. The firm lodges its own reports.

Open the Tranche 2 guide

Questions: team@freeaml.com.au