Suspicious Activity Reports

Find the source news @ https://www.nationalcrimeagency.gov.uk/what-we-do/crime-threats/money-laundering-and-illicit-finance/suspicious-activity-reports

Suspicious Activity Reports (SARs) alert law enforcement to potential instances of money laundering or terrorist financing. SARs are made by financial institutions and other professionals such as solicitors, accountants and estate agents and are a vital source of intelligence not only on economic crime but on a wide range of criminal activity. They provide information and intelligence from the private sector that would otherwise not be visible to law enforcement. SARs can also be submitted by private individuals where they have suspicion or knowledge of money laundering or terrorist financing.

SARs are not crime or fraud reports, if someone wishes to report a crime or a fraud they should contact either their local police service on 101 or Action Fraud on 0300 123 2040.

The value of SARs

The value of SARs is wide-reaching. SARs intelligence has been instrumental in locating sex offenders, tracing murder suspects, identifying subjects suspected of being involved in watching indecent footage of children online and showing the movement of young women being trafficked into the UK to work in the sex industry.

Some SARs provide immediate opportunities to stop crime and arrest offenders, others help uncover potential criminality that needs to be investigated, while others provide intelligence useful in the future. All contribute to the UK’s strategic threat assessment.

Information provided through SARs such as contact details, alias identities, investment activity, bank accounts and other assets can lead to the instigation of new investigations or enhance on-going operations.

SARs can help identify changes in the nature or prevalence of types of organised crime e.g. mortgage and boiler room frauds. This enables detection and prevention activity including the issue of alerts to businesses at risk from such activity.

Multiple SARs on the same subject or company can identify new targets for operational activity. Information leads to the recovery of the proceeds of crime by assisting in restraint orders, confiscation orders and cash seizures.

SARs provide intelligence about criminal methods, contribute to the UK’s understanding of crime and inform strategies to reduce the impact of crime.

SARs can also help establish a geographical picture or pattern of the vulnerability of a particular sector or product, and can be used in the analysis of suspicious activity before and after a specific event such as a terrorist incident.

Who can make a SAR?

Persons working in the regulated sector are required under Part 7 of the Proceeds of Crime Act 2002 (POCA) and the Terrorism Act 2000 to submit a SAR in respect of information that comes to them in the course of their business if they know, or suspect or have reasonable grounds for knowing or suspecting, that a person is engaged in, or attempting, money laundering or terrorist financing.

However, even if you are not in the regulated sector, you may have an obligation to submit a SAR. You may commit an offence if you have ‘knowledge’ or ‘suspicion’ of money laundering activity or criminal property, do something to assist another in dealing with it, and fail to make a SAR.

If you’re unsure if your firm is in the regulated sector consult your regulator, professional body or trade association, or seek independent legal advice.

Submitting a SAR protects you, your organisation and UK financial institutions from the risk of laundering the proceeds of crime.

How SARs are used

A single SAR is often used multiple times by different users for different purposes. For example, the information within a SAR may inform HM Revenue & Customs about taxation, local police about fraud or theft and a government department about an issue or weakness in a financial product.

Our UK Financial Intelligence Unit (UKFIU) receives more than 460,000 SARs a year. SARs are stored on our secure central database, which currently holds over two million SARs. We analyse the SARs to extract strategic and tactical intelligence, identify the most sensitive SARs and send them to the appropriate organisations for investigation.

The remainder are made available to UK law enforcement bodies via a secure channel (with the exception of SARs in certain sensitive categories).

Reporters of SARs would not routinely be provided with updates on their SARs and may only become aware of the existence of operational activity if law enforcement request further information from them.

Reporter Release new SAR data guidance

The following user guide has been created for the UKFIU, law enforcement agencies, and government departments to provide an overview of the new SAR fields: pdfNew Presentation of SAR data (Guide C (1.33 MB) ).

Make a SAR using the SAR Portal

The easiest way to submit a Suspicious Activity Report is with the new secure SAR Portal. The SAR Portal is free, negates the need for paper-based reporting, provides an instant acknowledgement and reference number (reports submitted manually do not receive an acknowledgement), and reports can be made 24/7. Online reports will also be processed more quickly, particularly if a defence against money laundering is sought.

Any organisation yet to register for the new SAR Portal can now do so, and immediately begin submitting Suspicious Activity Reports via the following link. Alternatively, the Portal can be accessed via the URL https://sarsreporting.nationalcrimeagency.gov.uk/.

Once an organisation has registered, it is expected that the new SAR Portal will become the sole route by which an organisation submits Suspicious Activity Reports.

It is recommended that registration is completed as soon as possible as the current SARs Online System is planned to be decommissioned later this year.

For further guidance on how to register for and use the new SAR portal, please review the supporting materials and user guides below.

Alternatively, you can download the below forms for manual reporting:

SAR Portal Feedback

New SAR Portal Feedback Form – Please use this link to provide any feedback you may have on the new SAR Portal, the overall onboarding process, and any potential improvements which can improve our service.

spreadsheetNew SAR Portal Feedback Form (Offline copy) (18 KB) – If you are unable to access the link above, please download and complete the offline copy of the new SAR Portal Feedback Form and return to UKFIUEngagement@nca.gov.uk.

New SAR Portal guidance

For the new SAR Portal, two user guides, two video guides and a FAQs document have been developed. The guidance materials have been created to help you get ready to use and familiarise yourself with the new SAR Portal.

Guides:

pdfNew SAR Portal Overview (Guide A) (1.81 MB) – Overview of the new SAR Portal for individuals and organisations that use the Portal to submit SARs.
pdfNew SAR Portal – How to register (Guide B) (1.77 MB) – Guidance on how to register to the new SAR Portal to submit SARs. All organisations and individuals will need to register.
documentThe role of the First Registrant (51 KB) – Guidance for the first registrant of a reporting organisation to enable both initial registration, and the registration of colleagues prior to using the new SAR Portal.

Videos:

How to register and sign in (Video 1) – Video guidance for individuals and organisations on how to register and ‘sign in’ to the new SAR Portal.
How to submit a SAR using the new SAR Portal (Video 2) – Video guidance on how to submit a SAR using the new SAR Portal.

FAQs:

pdfNew SAR Portal FAQs (432 KB) – Frequently asked questions for organisations and individuals that submit SARs.

Guidance on making a SAR

The quality of a SAR can affect our ability to prioritise and process the report. It can also affect the relevant agency’s decision or ability to investigate. Include as much detail as you can, even if it seems irrelevant, as it could become a valuable piece of information.

Poor quality reporting can lead to unnecessary delays, particularly where a defence against money laundering has been sought, and can cause face-to-face problems with your client, customer or supplier. For further information please see the guidance notes in the UKFIU documents library below.

See the UKFIU document Guidance on Submitting Better Quality SARs.

Request a defence under POCA and TACT

One of the core functions of the UKFIU is the receipt and processing of requests for a defence against money laundering or terrorism financing offences (otherwise known as ‘consent’, ‘appropriate consent’ or ‘prior consent’). The UKFIU receives over 22,000 such requests a year.

To request a defence please submit a SAR including all of the relevant information. This will enable us to analyse the request and, where necessary, seek advice from the relevant agency.

Please read pdfRequesting a defence under POCA TACT (221 KB) for further information.

Legal basis for reporting SARs

The UK’s anti-money laundering and counter terrorist financing network consists of primary and secondary legislation and industry guidance, designed to support Her Majesty’s Treasury, in accordance with Financial Action Task Force (FATF) international standards and EU Directives.

Primary legislation consists of POCA and TACT. Secondary legislation is the Money Laundering Regulations (MLRs) which supports the primary legislative objectives.

Those reporting to the UKFIU need to be aware of the ‘tipping off’ provisions (Section 333A-E of POCA) which makes it an offence, having submitted a SAR, to reveal information which is likely to prejudice any resulting law enforcement investigation.

It is a criminal offence in the UK to finance or facilitate the financing of terrorism and there are legal obligations to submit SARs as set out in Part III of TACT. There are offences for failing to make a disclosure under sections 19(2) and 21 of TACT.

SARs reporting in Northern Ireland

Part 7 of POCA applies throughout the UK; this aspect was not amended by Schedule 24, Crime and Courts Act (2013). Therefore POCA applies as it did before the NCA came into being. Notwithstanding other aspects of how the NCA operates in Northern Ireland, reports under Part 7 of POCA should therefore continue to be made to the UKFIU within the NCA.

SAR Confidentiality Breach Line

There is a dedicated helpline (0207 238 1860) for reporting sectors to raise any concerns about inappropriate use of SARs (by end users) or breaches of SAR confidentiality.

This is a 24 hour line available from Monday to Sunday. This number is for reporting breaches of confidentiality only.

When contacting the UKFIU SAR Confidentiality Breach Line, please only contact for this purpose and not for general UKFIU and SAR queries.

If you do require assistance with general UKFIU and SAR queries please contact the dedicated number on 0207 238 8282 or email UKFIUSARs@nca.gov.uk

If you require further information please contact UKFIU Disclosure Team UKFIU.DisclosureTeam@nca.gov.uk

Contact the UKFIU

The NCA is unable to give advice on whether or not an individual or organisation should submit a SAR. For queries of this nature please contact the appropriate anti-money laundering supervisor/regulator or seek independent legal advice.

020 7238 8282 – General UKFIU queries and SAR Online technical support only. This is a voicemail service only; please leave a message including the date, time, contact details, and the nature of your query and a member of the team will get back to you.

UKFIUSARs@nca.gov.uk – General UKFIU queries, SAR Online technical support.

DAML@nca.gov.uk – Urgent queries regarding or information updating current DAML requests only.

UKFIU.OperationalRiskManagementTeam@nca.gov.uk – queries regarding the disclosure of SARs during litigation or as part of a Data Subject Access Request.

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