Suspicious Activity Report Meaning: SARs in UK AML
In brief: A Suspicious Activity Report is a report made where relevant knowledge, suspicion, or belief about money laundering or terrorist financing arises.
Key points
- SARs are about suspicion or knowledge, not proof beyond doubt.
- In a firm, staff usually raise an internal report before any external SAR decision.
- The decision record should explain the facts, analysis, outcome, and follow-up.
What is a Suspicious Activity Report?
A Suspicious Activity Report, or SAR, is a report used to alert the UK Financial Intelligence Unit to possible money laundering or terrorist financing. The NCA SAR guidance describes SARs as a vital source of intelligence.
SAR meaning in a firm
For a regulated accountancy or law firm, SAR work normally starts internally. A staff member spots a concern and reports it to the MLRO or nominated officer. The MLRO reviews the facts and decides what to do next.
What should be in the record?
- Client or matter name.
- Facts that caused concern.
- Documents reviewed.
- Client explanation.
- Why suspicion may or may not exist.
- MLRO decision.
- Date, reviewer, and follow-up.
What not to do
Do not tell the client that a SAR is being considered or has been made. Do not keep vague notes such as "looks suspicious" without facts. Do not make a decision verbally and leave no record.
This guide is general information and is not legal advice.