Cassandra AML

International funds transfer instructions (IFTIs): who reports and why

4 minute read, updated

An international funds transfer instruction (IFTI) is an instruction to transfer money or property from Australia to another country, or into Australia from another country, in the course of carrying on a business of transferring funds or property. AUSTRAC uses two report types: IFTI-E for electronic funds transfer instructions and IFTI-DRA for transfers under a designated remittance arrangement. The obligation is not a suspicion-based report. It is a mechanical, time-limited report that applies when a reporting entity sends or receives the instruction. This guide explains the boundary so professional practices do not confuse IFTIs with threshold transaction reports or suspicious matter reports.

Who is captured

IFTI reporting sits with reporting entities that carry on a business of transferring money or property across Australia's border: banks, remittance providers, and other businesses whose designated services include an international funds transfer instruction. The instruction must be electronic for an IFTI-E, or under a designated remittance arrangement for an IFTI-DRA.

Most Tranche 2 professional practices - tax agents, lawyers, conveyancers and accountants - do not provide a cross-border transfer service themselves. A practice that merely receives a client's overseas payment as part of its fees is not providing an IFTI service. But a practice that operates a remittance or virtual-asset transfer service must check its own services against the reporting provisions rather than assuming the label 'professional services' excludes them.

The report and the deadline

The clock starts on the day the instruction is sent or received, not when settlement completes. Business days exclude weekends and public holidays, so practices with cross-border services should calculate deadlines in the same disciplined way they calculate TTRs.

  • Report each IFTI-E and IFTI-DRA within 10 business days after the day the instruction was sent or received
  • Include the ordering and beneficiary customer information the AUSTRAC reporting form requires
  • Keep the underlying instruction and customer due diligence records for the applicable retention period
  • Do not treat a large transfer as an SMR simply because it is international; assess suspicion separately

IFTI vs TTR vs SMR

A TTR is triggered by A$10,000 or more of physical currency connected to a designated service; it is about cash. An IFTI is triggered by a cross-border instruction; it is about the transfer mechanism. An SMR is triggered by suspicion and is due within three business days (24 hours for terrorism financing), with protected information subject to the tipping-off prohibition. One activity can generate more than one report: a suspicious $15,000 cash payment arranged as an international transfer may require a TTR, an IFTI and an SMR, each with its own test.

Practical controls

AUSTRAC has identified IFTI reporting as a common vulnerability. The practical fix is the same as for TTRs: a defined report type, a stable calculation of the deadline, validation before lodgement and an evidence trail showing when the obligation arose.

  • Classify each transfer product against the IFTI definitions before launch
  • Capture the send or receive date automatically and compute the due date
  • Validate ordering and beneficiary data before submission
  • Test the reporting path with AUSTRAC Online before it is needed in a live event

Official sources

Confirm the current rules against these primary sources.

Questions

Do lawyers and conveyancers need to report IFTIs?

Only if they provide a designated service that is an international funds transfer instruction in the course of carrying on a transfer business. Receiving an overseas client payment into trust is not, by itself, providing an IFTI service.

What is the difference between IFTI-E and IFTI-DRA?

IFTI-E is an electronic funds transfer instruction sent to or received from another country. IFTI-DRA is an instruction under a designated remittance arrangement where at least one participant is not a financial institution, such as a remittance network involving a non-bank.

When is an IFTI report due?

Within 10 business days after the day the instruction was sent or received. The deadline is calculated from the instruction event, not settlement.

Can an international transfer also require an SMR?

Yes. The IFTI is mechanical; the SMR is judgment-based. If the circumstances create reasonable grounds for suspicion, lodge the SMR within the applicable deadline and protect SMR-related information from tipping off.

General information for Australian professionals, not legal advice. It does not replace the AML/CTF Act, the Rules or AUSTRAC guidance. See our editorial standards.

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