Defence Against Money Laundering
A Defence Against Money Laundering — often called a 'consent SAR' — is a request to the NCA under POCA s.335 (or s.336 for terrorism) for permission to undertake an act that would otherwise be a principal money laundering offence. Approval is implied if the NCA does not respond within 7 working days (the 'notice period'); a refusal can be extended for a further 31 days (the 'moratorium period').
a DAML is required when an accountant knows or suspects criminal property is involved in a planned transaction (such as completing a property sale, releasing client funds, or distributing partnership profits) and continuing without consent would expose the firm to a POCA offence. The DAML pauses the work; communication with the client must avoid tipping off.
How different roles use Defence Against Money Laundering
A good definition should change the next action for the person reading it.
Partner or director
Check whether this term affects acceptance risk, fee scope, supervision exposure, or sign-off responsibility.
ContinueMLRO or compliance lead
Map the term to evidence, escalation, monitoring, training, and inspection readiness.
ContinueClient-facing team member
Use the plain-English explanation to ask better client questions and write clearer file notes.
ContinueOther terms that go with Defence Against Money Laundering
A Suspicious Activity Report is a formal disclosure made to the National Crime Agency (NCA) when a person in a regulated sector knows or suspects that someone is engaged in money laundering or terrorist financing. Filing a SAR provides a defence against money laundering offences. Failure to file when there is grounds to do so is itself a criminal offence.
Tipping off is the criminal offence under POCA s.333A of disclosing — to a client or any other person — that a SAR has been or is being filed, where the disclosure is likely to prejudice an investigation. It also covers disclosing the existence of a money laundering investigation. The offence carries up to 5 years' imprisonment. Limited defences exist, including disclosure within a regulated group, but they are narrow.
The National Crime Agency is the UK's lead agency for tackling serious and organised crime, including money laundering and terrorist financing. The NCA's UK Financial Intelligence Unit (UKFIU) receives all Suspicious Activity Reports filed by regulated businesses and uses them to build intelligence pictures that support criminal investigations across UK law enforcement.
Before you treat Defence Against Money Laundering as handled
- Confirm which regulation, policy, or internal procedure the term maps to.
- Document the decision or evidence trail in the client file, not only in email or chat.
- Escalate where the term indicates higher risk, sanctions exposure, PEP status, suspicion, or missing evidence.
- Keep the wording consistent across onboarding, review notes, training material, and inspection packs.
Put Defence Against Money Laundering into practice with Certivus
Knowing the term is the first step. Certivus gives you the workflows — client intake, CDD, EDD, PEP and sanctions screening, audit-ready records — to apply it across every client.
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