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A SAR, or Suspicious
Activity Report, is a way of informing financial authorities of any suspicions you
might have about the behaviour of a client or customer. Specifically, behaviour
which signals potential involvement in money laundering or terrorist financing activity.
In the UK, SARs are
regulated by the UKFIU (or UK Financial Intelligence Unit). They can be
submitted via the SAR Online System which is hosted by the National Crime Agency. Every year, the UKFIU then
releases an overview SARs report, to summarise the findings of the year’s total
SARs, and analyse key themes and trends in financial crime reporting.
Simply put, a SAR
is required whenever an individual working for a business that’s subject to
money laundering regulations sees suspicious activity.
So what constitutes
suspicious activity? It doesn’t have a universal appearance, and might look
different in every organisation or business. That being said, there are some
key factors it’s worth looking out for when it comes to spotting unusual or
suspicious behaviour. You’ll need to submit a SAR if you encounter any of these
red flags while working in the regulated sector:
Deposits of an exceptionally high value
Transactions which are out of the ordinary
in origin, destination or value
Transactions taking place overseas of a
Customer or client behaviour that breaks a
Transactions that don’t make any commercial sense
According to the National Crime Agency, anyone
working in the regulated sector is required by the Proceeds of Crime Act to submit a
SAR after witnessing suspicious behavior. However, even if you’re not working
for a company in this sector, you can still submit a SAR as as a private individual,
if you have knowledge of – or suspect – a money laundering offence.
If you notice any
behaviour which meets the descriptions above, you should raise your concerns
with your firm’s Money Laundering Reporting Officer. It’s then up to the MLRO to decide whether
or not your suspicions warrant a SAR filing. Once suspicious activity is
detected, financial institutions have 30 days to submit a SAR, or 60 days if
further evidence is required to supplement the report.
In the UK, there are over
460,000 SARs submitted every year, and collectively these reports contribute a
great deal of information to the efforts of financial authorities to tackle
money laundering and terrorism financing. SARs provide a valuable insight into
criminal methods, and can help to identify changing financial crime tactics;
information filed in a SAR could enable an existing investigation to be taken
further, or even lead to completely new investigations being opened.
As well as doing your part
to help with the global battle against financial crime, every financial
institution is legally obliged to report suspicious activity via a SAR, in line
with the POCA 2002, the latest EU Money Laundering Directives and
the 2017 Money Laundering Regulations. As well as banks, this also includes
other firms in the regulated sector, like solicitors, estate agents,
accountants and many others.
If your firm has a
nominated MLRO, it’s best practice to express your concerns to them directly,
so they can raise a SAR to report the relevant information. However, you can
file a SAR yourself, and there are several different ways of doing this.
Use the SAR Online System. This is a simple enough process – submit your SAR via the NCA portal,
and you’ll receive instant confirmation that your report has been received.
There’s no paperwork involved with this option; every step is carried out
Report a SAR
manually. If you choose to file your SAR manually, you’ll need to download and
print several different forms, fill them out by hand and return them to
the NCA via post or fax. Please note – you won’t receive any acknowledgement of
your SAR if you submit it this way.
When you submit a SAR, providing the right
information about the case can make all the difference. You’ll need to
summarise the suspicious activity, explain how it was detected – and give a few
details to identify the business or individual too. Here’s a more comprehensive
breakdown of the information you should cover in a SAR:
All the information gathered during
customer due diligence or KYC, including full name and date of
A detailed account of your
reasons for suspicion, in approximately 1500 words. You need to divulge who is
involved, what their role is, where and when the activity is taking place, how
the activity came to be, and why you’re suspicious of it.
When you’re explaining the
circumstances that led you to submit a SAR, put the events in clear
Don’t use acronyms or any
specific industry jargon, which could cause confusion.
Disclose any bank account or
transaction numbers that could assist the investigation clearly, and in
You can find more advice on submitting a SAR in
the NCA’s formal guide, or see some clear
example scenarios in this guidance from the US Financial
Crimes Enforcement Network (FinCEN).
SARs form a crucial
part of the detection and investigation of financial crime in the UK and
world-over, but ensuring your firm is AML compliant is the best way to
eliminate suspicious activity altogether.
a comprehensive selection of intelligent AML services, including everything
from KYC checks to adverse media screenings, right through to ongoing
monitoring. Our fully integrated app enables you to access these facilities
while you’re on the move,
providing you with a clear result for your potential client or customer in a
matter of seconds. Find out more about the SmartSearch platform over on our product