Suspicious Activity Reporting

Welcome to your complete Suspicious Activity Reporting hub, providing all you need to know about filing Suspicious Activity Reports, from the basics to more detailed guidance. This page is created and maintained by our London-based Economic Crime Advisory team.

The sections below help you to know when to file a Suspicious Activity Report (SAR), how to file a SAR and how the information you include in a SAR is used in the global fight against financial crime.

You can also download our guide to help build a robust SAR framework. Click here to download.

If there is something specific that we have not covered and you’d like to know about, please get in touch with Clarinda Woodford.

When to file a SAR

In this first section we answer what is a suspicious activity report, under what circumstances you should file one.

Suspicious Activity Reports (SARs) are formal reports which are filed by entities and/or private individuals to alert law enforcement to potential money laundering or terrorist financing. It is mandatory for a SAR to be filed in all or any cases where there is suspicion or knowledge of money laundering or terrorist financing.

In the UK, SARs are filed to the UK Financial Intelligence Unit (UKFIU), which is part of the National Crime Agency (NCA). When a SAR is filed, the UKFIU conducts further investigation into the known or suspected illicit activity.

SARs are confidential between the UKFIU and the party which has filed the SAR.

A SAR should not be confused with crime or fraud reports.

The term Suspicious Transaction Report (STR) is referenced in the Financial Action Task Force (FATF) Recommendations, whereas the term SAR is more commonly used in national legislation. Often, both of these terms are used interchangeably.

Strictly speaking, the term SAR is arguably considered more appropriate as it is broader than the term STR. The “T” in the term STR may imply that only transactional behaviour/activity can be deemed unusual/suspicious and indicative of potential money laundering or terrorist financing. Conversely, the “A” in the term SAR acknowledges that more general behaviour (such as a customer acting oddly in a branch) may also be of concern.

STRs should not be confused with Suspicious Transaction and Order Reports (STORs) which are reports required by EU regulation relating to insider trading and market manipulation.

There is no financial amount which triggers a SAR in the UK. A SAR should be submitted if a party has suspicion or knowledge of money laundering or terrorist financing, regardless of the amount or currency of a transaction. A SAR should also be filed even if there is no transactional value – for example if a customer is being evasive about their identity or acting oddly in a retail location).  

Some jurisdictions, like the US, adopt Currency Transaction Reports (CTR), either as well as or instead of SARs. A CTR is a mandatory report which must be filed to authorities to notify them of any and all currency transactions that exceed a certain amount. The UK does not operate an equivalent of a CTR approach.

No. SARs must be made by financial institutions as well as professionals such as solicitors, accountants and estate agents and also private individuals where they have suspicion or knowledge of money laundering or terrorist financing. Filing SARs is an obligation contained in Part 7 of the Proceeds of Crime Act 2002 (money laundering) and Part 3 of the Terrorism Act 2000 (terrorist financing).

For money laundering SARs, there are different pretences under which a SAR must be filed depending on whether the party filing the SAR is in scope for the UK Money Laundering Regulations or not. Parties in scope for the UK Money Laundering Regulations include credit and financial intuitions, casinos, legal firms and art market participants. For these parties, a SAR must be filed if there is knowledge, suspicion or reasonable knowledge for suspicion of money laundering. “Reasonable suspicion” means in instances where a party should reasonably have suspicion based on the training they receive and anti-financial crime controls which their organisation must implement to comply with the UK Money Laundering Regulations. If the party filing the SAR is not in scope for the UK Money Laundering Regulations, a SAR must be filed if there is knowledge or suspicion of money laundering.

For terrorist financing SARs, in all instances a SAR must be filed if there is knowledge or suspicion of terrorist financing.


How to file a SAR

In this second section we go into more detail, including how to file a SAR and explaining the role of The UK Financial Intelligence Unit.

SARs must be filed electronically via the NCA SAR Portal. As of 4 March 2024, the previous SAR filing system (SARs Online) was decommissioned, and access has now been permanently revoked for all reporters. The NCA SAR Portal is the single and only platform to be used.

SARs should be submitted by the Nominated Officer or their delegate(s).

Once a SAR has been filed, it remains confidential between the UKFIU and the submitter. Importantly, the subject of the SAR must not be told about the SAR, as this is an offence called ‘tipping off’.

The UK Financial Intelligence Unit (UKFIU) is part of the National Crime Agency (NCA) and sits within the National Economic Crime Command (NECC). The UKFIU receives all SARs submitted in the UK. Once it has received a SAR, the UKFIU performs further investigation and analysis and determines appropriate next steps depending on the content of the SAR. 

The UKFIU receives all SARs submitted in the UK, either via the SARs Online system or paper forms. The UKFIU has national responsibility for receiving, analysing and disseminating intelligence gained through SARs to share with law enforcement agencies domestically and internationally. The specific next steps taken by the UKFIU depends on the contents of each SAR, and so all SARs are treated on a case-by-case basis.

Some non-exhaustive examples of the next steps which may be taken by the UKFIU after receiving a SAR might be:

  1. Working with domestic police to seize criminal funds and assets
  2. Working with international police and/or security forces to share information/intel about organised crime operations
  3. Working with domestic or international safeguarding programmes to protect crime witnesses from negative repercussions.

Yes. Most countries have a national FIU. Non-exhaustive examples of other national FIUs include:

  • Australia - The Australian Transaction Reports and Analysis Centre (AUSTRAC)
  • France - Intelligence Processing and Action against Illicit Financial Networks Unit (TRACFIN)
  • Germany - Financial Intelligence Unit Germany (FIU)

The difference between the UKFIU and most other national FIUs is that others are usually affiliated with the national Treasury. For example, in the US, the domestic FIU is the Financial Crimes Enforcement Network (FinCEN), which is part of the US Treasury.

Conversely, in the UKFIU is affiliated with the UK Home Office.

The UKFIU acts as primarily a bureau function and rapidly disseminates SARs to police services, HMRC, the FCA, SFO, NCA colleagues and other partners for potential investigation.

The specific next steps taken by the UKFIU depends on the contents of each SAR, and so all SARs are treated on a case-by-case basis.

Some non-exhaustive examples of the next steps which may be taken by the UKFIU after receiving a SAR might be:

  1. Working with domestic police to seize criminal funds and assets
  2. Working with international police and/or security forces to share information/intel about organised crime operations
  3. Working with domestic or international safeguarding programmes to protect crime witnesses from negative repercussions.

The latest SARs Annual Statistical Report (April 2022-March 2023) notes that 859,905 SARs were received by the UKFIU during the period. This is a decrease of circa 40,000 from the prior period attributed to a reduction in SARs from high street banks. Notwithstanding this, the Report notes that SAR filing led to £272.7m being denied to suspected criminals over the period, and in the last two periods more funds have been denied through SARs than in the previous 6 years combined.

Reporters should include details of transactions that they know, suspect or believe to be related to the money laundering or terrorist financing in SARs. Reporters therefore need to decide on a case-by-case basis which transactions are relevant to the suspicion and thus should be included. individual/entity, even Sometimes it maybe relevant to report a chain of transactions, across multiple account holders and financial institutions.

The NCA Guidance

on Submitting Better Quality SARs provides more detail about the transaction information that should be provided, if available. This notes that, when the suspicion being reported relates to a financial transaction, the reporter should:

If the reporter is suspicious because the activity deviates from the normal activity for that customer/business sector, the reporter should briefly explain how the activity differs.

If the beneficiary/remitter of the transaction is believed to be complicit in the suspicious activity, the reporter should consider providing their details as an associate subject.

  • Include the relevant details of the beneficiary/remitter of the funds
  • Include, if known, the destination/originating bank details e.g. sort code, correspondent bank details (this is very important as it could identify the offender)
  • Accurately record the date on which the transaction has occurred/will occur
  • Clarify the type of transaction (e.g. online payment/receipt, debit or credit card, ATM withdrawal, cheque, electronic transfer (BACS/CHAPS, cash etc)
  • Explain why any transactions included are considered to be suspicious
  • If relevant to your business, include the subject's financial details (account numbers) and details of associates
  • Summarise cash amounts at the end of the report
     

If the reporter is suspicious because the activity deviates from the normal activity for that customer/business sector, the reporter should briefly explain how the activity differs.

If the beneficiary/remitter of the transaction is believed to be complicit in the suspicious activity, the reporter should consider providing their details as an associate subject.


How SARs are used

In this third section we explain how SARs are used, how a DAML SAR is different and why the new SAR portal is being introduced.

SARs have multiple uses in the world of crime detection, because they alert law enforcement to potential money laundering or terrorist financing.

Most SARs relate to crimes that have already been committed (or ongoing 'criminal conduct’).

Some non-exhaustive examples of the uses of SARs submitted are:

  • Supporting domestic and international investigations
  • Helping authorities to seize criminal funds and assets
  • Identifying (potential) victims which need support and safeguarding, such as child sex abuse cases or missing person investigations

SARs must be filed to the UKFIU “as soon as practicable”. This means that an internal investigation should take place promptly and without delay to determine whether a SAR should filed or not.

There is no specified timeframe in UK legislation which dictates how quickly a SAR must be filed. This is because an internal investigation undertaken by the submitter could take some time, especially if the case is particularly complex (e.g. if it involves a lot of counterparties). Therefore, the stance in the UK is that a SAR should be filed as soon as the submitter has reasonable information/evidence to develop knowledge or suspicion. 

SARs should be submitted by a firm’s Nominated Officer. This is a designated role under the Proceeds of Crime Act 2002 and Terrorism Act 2000, and must be an employee of the business or organisation (i.e. not an external consultant or contractor).

The Nominated Officer has the following responsibilities:

  • Receiving internal reports of suspicious activity from any employee in the business
  • Evaluating all internal reports received to determine whether there is (or is suspected to be) any indication of money laundering or terrorist financing
  • Reporting SARs (including DAML and DATF SARs) to the UKFIU
  • Ensuring that no transactions are executed/continued illegally

Commonly, the Nominated Officer role-holder is also the firm’s Money Laundering Reporting Officer (MLRO).

A Nominated Officer may have a designated delegate, who can also submit SARs on the Nominated Officer’s behalf when the Nominated Officer is away. This does not relieve the designated Nominated Officer of his/her duties on a permanent basis.

A Defence Against Money Laundering (DAML) can be requested from the NCA where a reporter has a suspicion that property they intend to deal with is in some way criminal, and that by dealing with it they risk committing one of the three money laundering offences set out in the Proceeds of Crime Act 2002 (POCA). An offence is not committed if consent has been received from the NCA.

As of 5 January 2023, an amendment came into force in POCA which raised the monetary threshold for which DAMLs may be requested from £250 to £1,000.

For terrorist financing, the equivalent of a DAML SAR is a Defence Against Terrorist Finance (DATF) SAR.

How to build a robust SAR framework

Download our guide to help ensure your SARs are most effective in the fight against financial crime

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BDO Economic Crime Advisory

Whatever your business, our London-based Economic Crime Advisory team has the experience to help. We have worked in financial services, betting and gaming, legal and professional services, the art market and real estate. We work closely with you to make sense of the regulatory requirements and what they mean for your business.

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To discuss how we can help please get in touch today with Fiona Raistrick, Michael Knight-Robson or Clarinda Woodford.

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