SMR Shadow Case
Firewall System
Suspicious Matter Reports are stored in a completely separate data structure. No SMR indicators appear on shared dashboards, matter lists, or notifications — protecting your firm from tipping-off offences under s123 of the AML/CTF Act.
How It Works
Tipping-off is a criminal offence under section 123 of the AML/CTF Act. If a person discloses that an SMR has been, is being, or will be made — and that disclosure could prejudice an investigation — they commit an offence. This means SMR data must be architecturally isolated, not just permission-controlled.
Sentine stores SMR data in a completely separate object structure from the matter. This is the Shadow Case system. The SMR shadow case links to a matter but is invisible to all non-AMLCO users. No indicator of SMR existence appears on any shared dashboard, matter list, export, or notification.
Only users with the AMLCO role can access the SMR console, create shadow cases, draft SMR narratives, and manage submission records. The AMLCO console is a dedicated interface with its own access controls, separate from the main matter management views.
Step by Step
Follow the structured workflow from start to finish.
Suspicion Identified
A team member identifies suspicious activity. The matter is escalated to the AMLCO for review — without creating any visible indicator on the matter itself.
Shadow Case Created
The AMLCO creates an SMR shadow case. This is a separate data object that links to the matter but is invisible to non-AMLCO users.
Narrative Drafting
Draft the SMR narrative within the shadow case. All draft content is restricted to AMLCO-only access.
Submission & Reference
Record the AUSTRAC submission reference ID and timestamp. The shadow case captures a point-in-time evidence snapshot.
Case Management
Track shadow case status (draft, submitted, closed) entirely within the AMLCO console. No status changes propagate to shared views.
Key Features
Everything you need for this workflow, built into the platform.
Separate Data Architecture
SMR data is stored in a completely separate object/table from the matter. Not just permission-controlled — architecturally isolated.
AMLCO Console
Dedicated interface for managing SMR shadow cases. Only AMLCO role holders can access this console.
No Shared Surface Indicators
Zero SMR indicators on shared dashboards, matter lists, exports, or notifications. Tipping-off prevention by design.
Submission Reference Storage
Record AUSTRAC submission reference IDs and timestamps alongside the shadow case for complete reporting records.
Evidence Snapshot at Filing
Capture a point-in-time evidence pack snapshot when the SMR is filed, preserving the exact state of evidence at submission.
AMLCO-Only Notifications
All SMR-related notifications route exclusively to AMLCO users. No alerts, emails, or dashboard indicators reach other staff.
Section 123: The Tipping-Off Offence
Under section 123 of the AML/CTF Act, it is a criminal offence to disclose that an SMR has been, is being, or will be made, where that disclosure could prejudice an investigation or proposed investigation. Sentine's Shadow Case system is designed to prevent tipping-off at the architectural level — SMR data is physically separated from matter data, ensuring that even accidental disclosure through shared interfaces cannot occur.
- AML/CTF Act s123 — tipping-off is a criminal offence
- SMR data must be object-separated, not just role-restricted
- No SMR indicators on shared dashboards, lists, exports, or notifications
- Only AMLCO role can access SMR shadow cases
Explore Related Features
See how this capability connects to the broader compliance workflow.
Audit Trail
SMR-related audit events are logged separately and visible only within the AMLCO console.
Learn moreEvidence Packs
Default evidence packs never include SMR data. AMLCO can generate restricted sensitive packs.
Learn moreAUSTRAC Reporting
SMR submission sits alongside TTR and IFTI as part of your AUSTRAC reporting obligations.
Learn moreProtect Your Firm from Tipping-Off
Architecturally isolated SMR handling — because permission controls alone are not enough.
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