When do I file a Suspicious Matter Report?
A written decision flowchart with 10 decision points that walks you from a possible red flag to either “file the SMR” or “file the no-SMR record”. Every step cross-references the relevant part of s.41 of the AML/CTF Act.
Includes worked scenarios so you can pressure-test the flow against situations a small AU firm actually faces.
We send the flowchart link once. No newsletter signup unless you ask for it. ABN 49 452 393 782.
What’s inside
- 10 decision points from red flag to SMR
- Every step cross-referenced to s.41 AML/CTF Act
- Reasonable-grounds test explained in plain English
- Tipping-off offence boundary
- Timing rule: 3 business days (24 hours for TF)
- No-SMR record template
- Worked scenarios for real estate, conveyancing, accounting
- Escalation path inside a small firm
Anchored to s.41 AML/CTF Act
Each decision point is mapped to the relevant subsection so the principal or Compliance Officer can defend the decision later.
Reasonable-grounds test
Demystifies the “suspects on reasonable grounds” standard. You do not need certainty; you do not need detective-level proof.
Founder accountable
Built by Ben Horne. If your scenario isn’t covered by the worked examples, reply to the delivery email and Ben usually responds within a few business days.
Want Caltury to draft SMRs for you?
A$99 a month plus GST. Free until 1 July 2026, no credit card to start.