Who can lodge an SMR - all staff or only the Compliance Officer (CO)?
Only the Compliance Officer can sign off and send the SMR to AUSTRAC; staff raise Unusual Activity Reports (UARs) which the CO reviews and decides whether to escalate.
Only the Compliance Officer can sign off the SMR and send it to AUSTRAC. Staff who notice concerns raise an Unusual Activity Report (UAR) which the CO reviews and decides whether to escalate to an SMR. AUSTRAC does not want the CO to discuss with staff whether the SMR was submitted - just confirm the UAR was closed.