SMR Reporting and Escalation Playbook for Accounting Firms
A practical suspicious matter reporting workflow for accounting firms. Includes free SMR escalation playbook, manager submission checklist, internal suspicion referral form, and record keeping checklist.
Last updated: 31 December 2025
Suspicious matter reporting is where firms freeze. The risk is not only missing a report, but also failing to document how you made the decision.
AUSTRAC states SMRs must be submitted within 24 hours if the suspicion relates to terrorism financing, or within 3 business days if the suspicion relates to other matters such as money laundering.
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Who this is for - Accounting firms designing internal escalation for SMRs - Compliance officers who want consistent referrals and clear evidence - Partners who want fast escalation with minimal disruption
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Related guides - Program, controls and evidence mapping - Readiness toolkit
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Table of contents
1. SMR timeframes and why timing matters 2. The internal escalation workflow 3. Example: a strong internal suspicion referral narrative 4. Common pitfalls that cause late reporting 5. Resources and downloads 6. How Nelvo can run this for you 7. FAQ 8. Sources
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SMR timeframes and why timing matters
| Suspicion type | Deadline | |----------------|----------| | Relates to terrorism financing | Within 24 hours | | Other suspicions (e.g. money laundering) | Within 3 business days |
The clock starts when suspicion is formed. If staff hesitate or are unsure who owns the next step, you lose time.
Your solution is a clear pathway and a referral form that captures facts quickly.
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The internal escalation workflow
Workflow overview:
1. Staff member forms a suspicion 2. Staff member completes an internal referral form immediately 3. Escalate to the compliance officer or delegated reviewer 4. Reviewer documents decision and rationale 5. If SMR is required, submit via AUSTRAC Online and record the submission reference 6. Update internal registers and store the evidence pack together
What staff must do: Staff do not decide whether to submit. Staff escalate quickly with facts.
What the reviewer must do: The reviewer decides, records rationale, and ensures timeframes are met.
What the compliance officer must maintain: A single evidence trail with referral, decision, supporting documents, submission receipt if submitted, and register entry.
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Example: a strong internal suspicion referral narrative
| Field | Example | |-------|---------| | Date and time suspicion formed | 14 May 2026, 3:15pm | | What happened | Client requested urgent restructuring advice and asked that invoices be split across multiple unrelated entities. Client declined to provide standard identity documents and pushed for work to proceed before verification. | | Why it is suspicious | Unusual urgency, reluctance to provide identification, and request to fragment payments across unrelated entities are inconsistent with normal engagement behaviour and may indicate attempts to conceal identity or source of funds. | | Documents attached | Email thread, engagement notes, draft invoice request |
This gives the reviewer enough to decide and enough to evidence the decision later.
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Common pitfalls that cause late reporting - No nominated reviewer and backup reviewer. If the primary person is unavailable, escalation stalls. - No time and date captured for when suspicion was formed. You cannot prove you met the deadline if you do not know when it started. - Evidence is not stored as one pack, so the story is fragmented. Keep referral, decision, documents, and submission receipt together in one folder.
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Resources and downloads
SMR workflow set - SMR escalation playbook (PDF) - Manager SMR submission checklist (PDF) - Internal suspicion referral form (Word) - Record keeping checklist (PDF) - AML CTF registers workbook (Excel)
Recommended supporting documents - Partner briefing (PDF) - CDD decision trees (PDF) - CDD templates (Word)
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How Nelvo can run this for you
A practical implementation looks like:
1. Define escalation roles and publish the pathway firm wide 2. Configure referral form and evidence pack structure 3. Build the SMR internal log and make evidence location mandatory 4. Train staff using scenarios relevant to your work 5. Run a monthly triage review to identify patterns and program gaps
Outcome: reporting becomes routine, not panic.
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FAQ
What is the biggest cause of late reporting? No clear internal pathway. People hesitate because they do not know who owns the next step.
Should staff tell the client? Do not improvise. Escalate internally and follow your program and AUSTRAC guidance. Treat it as confidential within your firm.
What do we do if the suspicion turns out to be nothing? Document the decision and rationale and close it out. Evidence of review is still valuable.
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Sources - AUSTRAC suspicious matter reports guidance - AUSTRAC submitting your SMR, includes timeframes - AUSTRAC reporting overview - AUSTRAC record keeping - AML CTF Act 2006
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Important note
This guide is general information only. It is not legal advice. Tailor to your firm and obtain advice where needed.