MLRO and SAR reporting workflows

Practical resources for firms that need clear internal reporting routes and defensible MLRO decision records.

How the SAR pipeline works

Staff who know or suspect money laundering make an internal disclosure to the nominated officer. The MLRO considers it and decides whether to report to the NCA, and whether consent is needed before proceeding. The duty on individual staff comes from POCA 2002 and exists whether or not the firm has a process.

Recording decisions not to report

A decision not to submit a SAR is a decision, and it needs the same record as one to submit. Where an MLRO considered a concern and concluded no suspicion arose, that reasoning is what evidences the pipeline worked. Tipping-off constraints apply throughout and shape what can be said to the client.