What is a suspicious activity report?
A Suspicious Activity Report (SAR) is a report filed with the relevant Financial Intelligence Unit (FIU) when a business suspects or has reasonable grounds to suspect money laundering or terrorist financing. In the UK, SARs are filed with the National Crime Agency (NCA). Failure to file a SAR when required is a criminal offence under the Proceeds of Crime Act 2002.
When to file a SAR
A SAR is needed when you know or suspect, or have reasonable grounds to know or suspect, that someone is laundering money.
The suspicion threshold
A SAR must be filed when there is knowledge or suspicion, or reasonable grounds for knowledge or suspicion, that a person is engaged in money laundering. The threshold is not proof - it is suspicion, which is a significantly lower standard.
Common triggers
- A confirmed match on a sanctions list
- Inability to verify customer identity or beneficial ownership
- Transactions inconsistent with the customer's known business profile
- Unexplained source of wealth or funds
- Connections to high-risk jurisdictions
The SAR process
Internal reports are made to the MLRO, who evaluates the information and determines whether the threshold for external reporting is met. If so, the MLRO files a SAR with the NCA. In cases where consent is needed to proceed with a transaction (a "consent SAR"), the NCA has 7 working days to respond.
FirmScreen supports the SAR process by providing detailed match reports and audit trails that document the screening results triggering the suspicion.
Tipping off
It is a criminal offence to "tip off" a person that a SAR has been filed or that an investigation is being considered. This restriction applies to all staff, not just the MLRO. Firms should ensure their AML training covers tipping-off obligations.
Related terms