Introduction to Suspicious Activity Reports (SARs) 

This is a United Kingdom Financial Intelligence Unit (UKFIU) Guidance Note. It is produced in line with the National Crime Agency (NCA) commitment to share perspectives on the Suspicious Activity Reports (SARs) regime. 

Revised May 2014

Overview 

This document seeks to provide an introduction to the Suspicious Activity Reports (SARs) regime. More in-depth advice and guidance on the submitting of SARs can be found from the UKFIU section of the National Crime Agency (NCA) website – www.nationalcrimeagency.gov.uk. See also the UKFIU Guidance Note, ‘Submitting A SAR Within The Regulated Sector’. 

What is a SAR? 

A SAR is a Suspicious Activity Report, a piece of information which alerts law enforcement that certain client/customer activity is in some way suspicious and might indicate money laundering or terrorist financing. 

Reason for suspicion 

Submitting a SAR provides law enforcement with valuable information on potential criminality. It also protects you, your organisation and UK financial institutions from the risk of laundering the proceeds of crime. 

By submitting a SAR to the NCA, you will be complying with any potential obligations you have under the Proceeds of Crime Act 2002 (POCA). 

When do I submit a SAR? 

As soon as you ‘know’ or ‘suspect’ that a person is engaged in money laundering or dealing in criminal property, you must submit a SAR. 

Do I have to submit a SAR if I am not in the regulated sector? 

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. 

Submitting a SAR provides a defence against committing a money laundering offence.

Is the information contained in the SAR I submit held securely? 

All users of SARs adhere to specific guidelines to protect the confidentiality of SARs. Once a SAR is received by the NCA, it is held on a secure database. This database has strictly limited access to appropriate law enforcement and government agency staff. THE INFORMATION IS ALWAYS HELD IN THE STRICTEST CONFIDENCE. If, in the unlikely event you are made aware that any confidentiality may have been breached, you should contact the NCA immediately. This should be done via MolyMed Supplies service email. admin@molymedsupplies.com

May I inform a client/customer that I have made a report? 

You must not say anything to your client/customer which leads to an investigation being prejudiced. If that provides you with particular difficulties, you can seek guidance from the NCA. In certain cases, a form of words can be agreed that may overcome problems. 

What is consent in relation to SARs? 

Persons and businesses generally, and not just those in the regulated sectors, may avail themselves of a defence against money laundering charges. This can be done by seeking, via a SAR, the consent of the NCA UK Financial Intelligence Unit (UKFIU). This consent is to conduct a transaction or undertake other activity about which they have concerns. The legislation gives the NCA seven working says to respond. Where the NCA refuses consent, the transaction or activity must not proceed for a further 31 calendar days. Or, if earlier, until further notified by the NCA.

Submitting A Suspicious Activity Report (SAR) within the Regulated Sector 

This is a United Kingdom Financial Intelligence Unit (UKFIU) Guidance Note. It is produced in line with the National Crime Agency (NCA) commitment to share perspectives on the Suspicious Activity Reports (SARs) regime.  Please see “Submitting a SAR”