What is a Suspicious Activity Report?

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.

When is a SAR required? 

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 high value

• Customer or client behaviour that breaks a consistent pattern

• Transactions that don’t make any commercial sense

Who can raise a SAR?

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. 

Why is raising a SAR important?

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.

How to Raise a SAR

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 online.

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.

Example of a SAR

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 birth.

• 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 chronological order.

• 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 standard format.

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).

How can SmartSearch help?

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.

SmartSearch offers 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 overview page.