Suspicious Activity Reporting (SAR)

Those working in the regulated sector are required under Part 7 of the Proceeds of Crime Act 2002 (POCA) and the Terrorism Act 2000 (TACT) to submit a Suspicious Activity Report if in the course of their business they know, suspect, or have reasonable grounds for knowing or suspecting, that a person is engaged in, or attempting to engage in, money laundering or terrorist financing.

According to Vince O’Brien, Head of the UK Financial Intelligence Unit (UKFIU) “SARs are vital to the fight against money laundering, illicit finance and wider criminality”. 

UKFIU reported that in the last financial year:

• 901,255 SARs were received and processed – a 21% increase on the previous year.
• £305.7M denied to suspected criminals as a result of Defence Against Money Laundering (DAML) requests – a 120.6% increase on the £138.6M denied in 2020-21.

The UKFIU website contains additional helpful information on the submission of SARS including a Frequently Asked Questions booklet.

Importantly, Notaries must demonstrate that they are submitting good quality SARS. The Faculty Office would therefore urge you to read the following helpful guidance produced by the NCA to help improve the quality of the SARs submitted:

• SARs Regime Good practice (PDF 15 pages, 238KB)  
• Guidance on submitting better quality SARS (PDF 23 pages, 397KB)
• The correct glossary codes for reporting (PDF 25 page, 522KB)
• Requesting a defence from the NCA under POCA and TACT