Under section 43 of the AML/CTF Act, if a reporting entity provides a designated service to a customer which involves the transfer of physical currency or e-currency of AUD10,000 or more (or the foreign currency equivalent), the reporting entity must submit a threshold transaction report (TTR) to AUSTRAC. From 1 October 2011 reporting entities will be required to include details of the individual conducting the threshold transaction where that individual is not the customer of the designated service. Regardless of their TTR obligations, reporting entities also have suspicious matter reporting (SMR) obligations. All reporting entities should have in place appropriate risk-based systems and controls to identify and analyse any unusual deposits made by customers into their bank accounts relating to the provision of a designated service. Where a reporting entity forms a suspicion about the deposit, they are required to submit a SMR to AUSTRAC under section 41 of the AML/CTF Act.
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