NCA Suspicious Activity Reports Annual Report 2025–2026: What does it mean for notaries?

The National Crime Agency (NCA) has published the UK Financial Intelligence Unit’s (UKFIU) Suspicious Activity Reports (SARs) Annual Report for 2025–2026. The report highlights the important role that financial intelligence plays in tackling money laundering and terrorist financing, and reinforces the need for effective anti-money laundering (AML) controls and appropriate reporting.

The report is available on the NCA website – Publications.

SARs reporting across the UK

During 2025–2026, the UKFIU received 896,414 SARs, an increase of 3% on the previous year. The report also records that £440.8 million was denied to suspected criminals through the Defence Against Money Laundering (DAML) regime, representing a 15% increase.

The legal sector accounted for 0.45% of all SAR submissions. Within the notarial profession, approximately 3% of notaries reported having submitted at least one SAR during the reporting period. This represents the number of individual notaries who made a report, rather than the total number of SARs submitted, as some notaries may have submitted more than one.

The relatively small number of reports from notaries is not, in itself, unexpected. The nature and scope of notarial work mean that notaries will generally encounter different levels and types of money laundering risk compared with some other regulated sectors. The notarial profession is generally considered to have a relatively low inherent risk of money laundering.

However, the number of SARs submitted should not be viewed in isolation. The UKFIU makes clear that supervisors are responsible for assessing whether reporting volumes are proportionate to the money laundering and terrorist financing risks associated with the sector they supervise.

For the Faculty Office, the important consideration is therefore not simply how many SARs are submitted, but whether notaries can recognise suspicious activity, make appropriate and informed reporting decisions, and demonstrate that their AML obligations are being met.

A low number of SARs does not automatically indicate effective compliance, just as a higher number does not necessarily demonstrate better compliance. The emphasis must be on the quality, justification and appropriateness of reporting, rather than the volume of reports submitted.

Understanding when a SAR is appropriate

The report also serves as a reminder that submitting a SAR should be based on genuine suspicion, rather than a defensive approach to reporting.

Case study: A defensive SAR submission

A review of a notary’s SAR found that the report had been submitted on an entirely defensive basis, without any specific underlying suspicion of money laundering.

The notary had made the report because the client was from a high-risk jurisdiction and was serving a prison sentence in a high-security prison. However, there was no evidence on the notary’s file that open-source checks had been undertaken to establish the circumstances of the client’s incarceration. Such enquiries may have helped inform the notary’s assessment of the circumstances and whether there were grounds for suspicion.

Outcome

The notary acknowledged that there had been no specific reason to suspect money laundering and accepted the criticism that the referral had been unnecessary. Importantly, the notary subsequently demonstrated insight and reflection, together with an increased understanding of the requirements for submitting a SAR.

This case illustrates the importance of taking a considered, risk-based approach. Notaries should neither overlook genuine concerns nor submit reports simply as a precaution where there are no grounds for suspicion. Decisions should be based on the circumstances of each case, with appropriate enquiries undertaken where possible and the reasoning clearly documented.

The Faculty Office has also discussed the grounds for submitting a SAR in more detail in its Regulation Matters podcast.

Remaining alert to financial crime risks

Fraud continues to represent a significant concern. The UKFIU report identifies fraud as accounting for 42% of inbound and 31% of outbound international requests handled by the unit. These figures demonstrate the continuing importance of financial intelligence in supporting cross-border investigations into economic crime.

Although the overall money laundering risk associated with notarial work may be relatively low, notaries should remain alert to circumstances in which their services could be misused. Transactions involving corporate arrangements, powers of attorney, overseas dealings and identity verification may, in certain circumstances, raise concerns about the parties involved, the source of funds or the underlying purpose of a transaction.

What should notaries take away from the report?

The report is a timely reminder that effective AML compliance is about more than the number of SARs submitted. Notaries should ensure that:

• They remain alert to potential money laundering and terrorist financing risks in the course of their work.
• They understand the circumstances in which a suspicion may arise and when a SAR is required.
• They take a proportionate, risk-based approach to assessing unusual or potentially suspicious activity.
• Appropriate enquiries are undertaken where relevant and possible to inform decision-making.
• Decisions, including the reasons for submitting or not submitting a SAR, are properly recorded and supported by evidence.
• Their AML policies, procedures and training remain effective and up to date.

The Faculty Office does not expect notaries to submit SARs simply to increase reporting numbers. It expects notaries to understand their reporting obligations, identify genuine concerns and make well-informed, properly documented decisions. The quality and appropriateness of reporting, rather than the volume of submissions, remain the key considerations.