Suspicious Activity Reporting Guidance
Money Laundering Reporting Officers (MLROs)/nominated officers of firms and sole practitioners have a legal obligation to submit a Suspicious Activity Report (SAR) where there is knowledge or suspicion of Money Laundering (ML) or Terrorist Financing (TF). SARs alert law enforcement to the suspicious activity and provide valuable information about the potential ML/TF to support investigations.
How to submit a SAR
SARs are submitted through the National Crime Agency (NCA) SAR portal which can be found here - https://sarsreporting.nationalcrimeagency.gov.uk/. Firms/sole practitioners should register with the SAR portal even if you are not currently considering making a SAR, as this ensures you are ready if a SAR ever needs to be made. Register with the SAR portal here - https://sarsreporting.nationalcrimeagency.gov.uk/register
SAR Quality
Submitting a good quality SAR is important for the NCA to effectively prioritise and process reports. The NCA have published a guidance document on submitting better quality SARs which can be found here - https://www.nationalcrimeagency.gov.uk/who-we-are/publications/650-guidance-on-submitting-better-quality-suspicious-activity-reports-sars-v9-0/file
Some good practice points include:
- Use SAR glossary codes - these help the NCA to identify high-risk priorities, enable them to take immediate action where necessary and enable them to analyse emerging ML/TF trends.
- Be clear and concise – include a clear reason for suspicion, avoid using acronyms and jargon.
- Details are important – SAR quality is improved where details are provided such as full names, dates of birth, nationality, addresses, passport details, driving licence details, National Insurance numbers, registration numbers, phone numbers, bank account details etc.
- Include all available Customer Due Diligence (CDD) information to assist with identifying individuals correctly.
- Complete all SAR information fields - use the word ‘unknown’ if you do not know the information for a particular field. Do not leave fields blank or use any other characters.
- If the reported subject has been the subject of a previous SAR, include the previous SAR reference to enable the NCA to connect the reports.
- Clearly identify the suspected benefit from criminal conduct (criminal proceeds/property) and where possible the amount.
SAR reporting procedures and record keeping
Firms must include internal SAR reporting procedures in their practice AML policies and procedures to enable staff and relevant agents/sub-contractors to disclose their knowledge or suspicions of ML/TF to the MLRO. CIOT policies and procedure proforma documents can be found here, which firms may wish to consider when reviewing their policies.
MLROs are required to consider all internal SARs and submit a SAR to the NCA where they suspect ML/TF. Records of internal SARs and notes of matters considered for reporting, even if no report has been made, should be kept. Firms/sole practitioners must retain copies of all Suspicious Activity Reports submitted to the NCA so the CIOT can inspect these as part of supervisory activity. SAR reports should be retained separately from client files in secure MLRO records – this helps to prevent the risk of tipping off.
DAMLs and DATFs
A Defence Against Money Laundering (DAML) or Defence Against Terrorist Financing (DATF) is a disclosure made to the NCA where a reporter has a suspicion that property they intend to deal with is in some way criminal property, and that by dealing with it they risk committing one of the principal money laundering or terrorist financing offences under Proceeds of Crime Act 2002 (POCA) or Terrorism Act 2000 (TACT). A reporter may submit a DAML or a DATF where they wish to request a defence to one of these offences before dealing with the criminal property in question. Further information on requesting a defence from the NCA under POCA and TACT can be found here - https://www.nationalcrimeagency.gov.uk/who-we-are/publications/717-requesting-a-defence-under-poca-and-tact/file
Note that the NCA sometimes receive DAMLs where firms cannot complete client due diligence or asking whether it is OK to continue to act for a client. A request to commence or maintain a business relationship will not be considered, as the request is too broad. Whether or not to take on/maintain client relationships is a business decision for reporters to make based upon their own risk appetite.
Further SAR Guidance links
Questions 62-66 of the CIOT AML FAQs https://www.tax.org.uk/aml-frequently-asked-questions provide guidance on SAR reporting and responsibilities. The question covered are:
Q62. How do I make a Suspicious Activity Report (SAR)?
Q63. What are the responsibilities of staff in relation to making a SAR?
Q64. What are the MLRO’s responsibilities once they have received an internal suspicious activity report from staff?
Q65. Several other parties are acting for a client in relation to a transaction. As one of the other parties is likely to be making a SAR do I need to do one as well?
Q66. I have a suspicion about someone who never became a client. Is there a responsibility to do a SAR?
The UKFIU recently joined our AML webinar to present on the SAR portal and SAR quality. A recording of this webinar, as well as previous AML webinars are available on the CIOT webpage.
AMLGAS
Section 6 of Anti-Money Laundering Guidance for the Accountancy Sector (AMLGAS) provides further information on SARs.
Members may also find it helpful to refer to the supplementary guidance for tax advisers which is available here https://www.ccab.org.uk/wp-content/uploads/2022/05/SupplementaryGuidanceTaxPractitioners_2019Version.pdf and includes guidance for tax practitioners on tax offences, SARs and the privilege reporting exemption.
NCA Guidance
New SAR Portal Overview (User Guide A)
New SAR Portal - How to Register (Guide B)
New SAR Portal Guidance Signpost
Guidance on submitting better quality Suspicious Activity Reports (SARs) v9.0
Glossary Codes and Reporting Routes
If members have any further queries regarding Suspicious Activity Reports, please contact [email protected]
Last updated 21 May 2025