Threshold transaction report: the $10,000 cash rule

The $10,000 figure is a cash rule, not a deal-size rule. Checked against AUSTRAC’s threshold transaction reports page on 2 October 2026. This is general information, not legal advice, and it is not a copy of the Act. You only reach this report if you are providing a designated service. That map is /tranche-2 and the designated services decision tree.

What the $10,000 counts

AUSTRAC says you submit a threshold transaction report if you provide a designated service involving the transfer of $10,000 or more in physical currency. Physical currency means cash, such as bank notes or coins. Receiving it counts. Paying it counts. Foreign currency of the same value counts. A transfer by electronic funds, card, or cheque is not this report, even when the amount is far above $10,000.

• One transaction. AUSTRAC says a transaction is a single payment, even if it covers more than one service. You report each physical-currency transaction of $10,000 or more.
• Do not add separate payments together. Separate physical-currency payments are not combined for the threshold, even if they happen close together or at another place. Their page has the examples.
• The clock. Lodge within 10 business days after the day the transaction takes place. The day itself depends on the service. Use their page if the product is unusual.

The property myth

A contract price above $10,000 is not a threshold transaction. AUSTRAC’s own example is a buyer who gives a real estate agent $21,250 in physical currency as a deposit, then later pays the settlement balance by electronic transfer into the agent’s trust account. The cash deposit is the threshold transaction. The agent lodges within 10 business days after that day. The electronic settlement is not a second threshold transaction report.

Most agency work never sees that cash. Say so in the program, and say what you would do if a deposit arrived in notes. Who must do customer due diligence on that listing is a different question: AML for real estate agents. The customer on a brokered sale is who is the customer. Neither page turns the purchase price into a cash report.

The trust myth

A trust does not create a threshold transaction by existing. A distribution from a family trust, a balance sitting in a solicitor’s trust account, and an electronic payment into that account are not physical currency. AUSTRAC’s example already makes the point: the electronic payment into the trust account was not a second report. If the firm receives $10,000 or more in notes or coins while providing a designated service, the trust account is just where the cash landed. The cash is the report.

Accountants hit the same myth from the other side. A tax return or a set of financial statements is not a cash transfer. Whether the engagement is a designated service at all is AML for accountants. If you do not receive or pay physical currency in that service, you do not invent a threshold transaction report to look thorough.

A split can be a different report

AUSTRAC says structuring — dividing physical currency so the pieces stay under the threshold — is a common money-laundering technique and a criminal offence. Separate payments under $10,000 are not, by themselves, added into a threshold transaction report. If you suspect on reasonable grounds that the split was made to avoid the report, you lodge a suspicious matter report. That test, and the clocks, are when a suspicious matter report is required. This page does not describe how to divide a payment.

Where FreeAML fits

FreeAML does not lodge a threshold transaction report and does not charge a filing fee for one. There is nothing to buy on this report. The reporting entity lodges it in AUSTRAC Online. When the program requires a customer check on the person who handed over the cash, or on any other customer of the designated service, the firm suite is A$0 and verification is client-pays by email. Amounts are on FreeAML pricing. The check is customer due diligence. It is not the threshold transaction report. How the program should mention cash is how to write the AML/CTF program.

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