After the SMR, you do not tell the customer and you do not wait for a verdict

People ask what happens next because lodging feels like sending a file into a void. Checked against AUSTRAC's suspicious matter reports guidance on 5 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. How Tranche 2 firms meet the duty is suspicious matter reports under Tranche 2. What you must not say is tipping off. The mechanics of the form are the SMR filing guide. The sector map is /tranche-2.

The lodgement is the end of your waiting

AUSTRAC's guidance says a suspicious matter report alerts authorities to possible money laundering, terrorism financing, proliferation financing and other crime. You submit one when you suspect on reasonable grounds that information you have may be relevant to crime, that a customer or their agent is not who they claim to be, or that a person is planning a money laundering or terrorism financing offence using a designated service. The suspicion can concern tax evasion or other Commonwealth, state or territory offences. You do not need to be certain. The obligation can arise when you propose to provide a designated service, or when someone asks for one, even if you never provide it.

The timeframe is part of the answer to “what happens next”, because the next thing is the clock you already started. Terrorism financing: 24 hours from forming the suspicion. Other suspicions: 3 business days after the day you formed it. If you claim the report includes information protected by legal professional privilege, AUSTRAC says you have up to 5 business days after the day you form the suspicion, and that longer period does not apply to terrorism financing. Once it is submitted, the pages read for this article do not describe a receipt that tells you whether the customer will be investigated. AUSTRAC has said, in its reporting material, that it uses the information in the report together with other information. Treat silence as the ordinary case. Do not chase a verdict you can then be tempted to share.

What you do inside the firm

• Limit who knows. The compliance officer and the people who must act. Not the reception desk, and not the client.
• Do not invent a status update. “We're waiting to hear from AUSTRAC” is how a tipping-off conversation starts.
• If you continue, enhance the due diligence. AUSTRAC's own table says that continuing the designated service means enhanced customer due diligence in line with your policies.
• If identity fails, stop. Where you cannot establish a required matter on reasonable grounds, you must not provide the designated service. A suspicion that the customer is not who they claim to be is itself a reason to report.
• A new suspicion is a new report. Reporting once does not retire the customer from later reports.

Enhanced due diligence is the live file

Enhanced customer due diligence is not a second copy of the same passport check. It is the extra work your program says you do when the risk, or the suspicion, requires it. That can include a clearer account of source of funds or source of wealth where the rules and your program make those relevant. It can include a decision by the officer to continue or to refuse. Write the decision down. The report you already lodged does not replace that note, and the note must not be emailed to the customer as an explanation of the report.

FreeAML does not see your suspicion and does not lodge it. If you still need to establish identity, the firm emails a link and the client pays. A clear identity result does not cancel a suspicion about the money. A hit on a screening list does not, by itself, complete the report. The officer writes the suspicion. AUSTRAC Online takes the report. The customer hears neither.

Where this page stops

This page is the period after lodgement. It is not a catalogue of red flags. Examples of how a firm talks to clients without crossing the line sit in how to talk about AML with clients.

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. There is no subscription. Confirm the live amounts on FreeAML pricing. FreeAML does not charge to lodge an SMR because it does not lodge one. Any KYC or KYB check is client-pays and is not a report.

Frequently Asked Questions