Submitting Suspicious Activity Reports (SARs) is a critical part of anti-money laundering (AML) compliance. The UK Financial Intelligence Unit (UKFIU), part of the National Crime Agency (NCA), is the only body authorised to receive SARs. Here’s what small firms need to know:
The full UKFIU guidance on submitting a SAR can be found here.
What SARs Are – and Are Not
- SARs report suspicions of money laundering or terrorist financing under POCA and TACT.
- They are not crime reports. You must still report crimes or safeguarding concerns to the police or relevant agencies.
- If you’ve reported to the police, include reference numbers in your SAR.
Why SARs Matter
- SARs help law enforcement disrupt criminal networks and protect national security.
- Submitting a SAR may provide your firm with a legal defence against certain offences.
- Failure to report when legally required can lead to prosecution and regulatory action.
When to Submit
- As soon as practicable after forming a suspicion.
- If you suspect both money laundering and terrorist financing, submit two separate SARs.
- Suspicion means “a possibility, more than fanciful, that the relevant facts exist” (R v Da Silva).
Best Practice for SARs
- Complete all relevant fields in the SAR Portal accurately.
- Keep your reason for suspicion clear and concise—who, what, when, why.
- Include details of criminal or terrorist property (type, value, location).
- Do not upload attachments—state if further information is available on request.
Quick Checklist for Writing a SAR
- Confirm suspicion relates to money laundering or terrorist financing (not general crime).
- Decide correct legislation: POCA or TACT.
- Gather all identifying details for main and associated parties (names, DOB, addresses, accounts).
- Clearly describe criminal or terrorist property (type, value, location).
- Write a concise reason for suspicion: who, what, when, why.
- Include any known law enforcement interest and reference numbers.
- Add suspicious transactions in the correct fields (not just in free text).
- Save or print a copy before submission (you cannot access it later).
- Store SAR securely in line with POCA, TACT, and data protection laws.
Useful Contacts
- General SAR guidance: UK*************@*****ov.uk
- Technical support: UK*******@*****ov.uk
- DAML requests: DA**@*****ov.uk
- Terrorist financing queries: UK******@*****ov.uk