Who files a TTR with AUSTRAC when cash hits a trust account

A threshold transaction report is the firm’s report to AUSTRAC about physical currency in a designated service. People then ask a second question: the money was receipted to the trust account, so whose name goes on the form? Checked against AUSTRAC’s threshold transaction reports page on 2 October 2026. This is general information, not legal advice. The cash rule, the 10-business-day clock, and why an electronic settlement is not a second report are the $10,000 threshold transaction report. Do not use this page as that explainer. Whether you provide a designated service at all is /tranche-2.

The reporting entity files, not the account

AUSTRAC says the business that provides a designated service involving the transfer of physical currency submits the threshold transaction report. A solicitor’s trust account, a conveyancer’s trust account, and a real estate agency account are places the money is held. They are not reporting entities. Writing the account name on the receipt does not choose who lodges.

The customer does not lodge it for you. A bookkeeper does not lodge it unless the program authorises that person to complete the report for the reporting entity. AUSTRAC’s form asks for the individual completing the report, or, if a system produced it, an individual accountable for it. That is a name inside the firm, not the payer.

Who files when the cash hits the account

Two firms can both be right. The agent who took a cash deposit files for that service. The conveyancer who later receives only an electronic balance does not file a second report for the electronic payment. If each firm received physical currency in its own designated service, each files its own. AUSTRAC’s worked example is summarised on the $10,000 page. This page does not restate it.

Who inside the firm completes it

The reporting entity is the practice, not a spare inbox. The AML/CTF program should name who gathers the receipt and who is accountable for the report that goes to AUSTRAC. In a small firm that is often the compliance officer. How one person can hold that role is the sole trader compliance officer. Staff who see the cash still have to pass the fact across the same day. That path is training, not a customer conversation.

Lodge in AUSTRAC Online. If you enrolled after 30 March 2026, AUSTRAC says you use the new form. Confirm the form note on their page. If you suspect the cash was split to stay under the line, that suspicion is a suspicious matter report, not a creative threshold report. The test is 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 the report itself. 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 wedge is that check. It is not a cash-reporting product. Who must be checked on a listing is AML for real estate agents.

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