The Court of Appeal case of HSBC v Shah[1] predictably hit the headlines in the legal and financial press in February of this year resulting in an outcry. The facts and implications were widely reported. Seemingly, anyone within the regulated sector who fails to take reasonable care when submitting a suspicious activity report (SAR) to […]

This summer domestic matters have dominated the AML policy landscape as the Brussels summer recess put paid to any further progress of note on the fourth EU Money Laundering Directive (4MLD). 4MLD I will provide a brief update on the latest timetable suggested for the passage of 4MLD. We are expecting that the MEPs working […]

The National Crime Agency has issued a notice stating that, from 15 September, a suspicious activity report requesting consent to continue with a financial transaction that fails to contain the reasons for suspicion or a statement regarding criminal property will be rejected. The reporter will be sent a notification letter setting out the reasons why […]

The instruction has been issued as a result of amendments made to the legislation surrounding the reporting of suspicion. The existing Handbooks are in the course of being reviewed and therefore to minimise the impact, and to avoid reprinting the full Handbook while the development continues, replacement pages of the Handbook for Financial Services Businesses […]

The NCA has published a new guidance note from the United Kingdom Financial Intelligence Unit (UKFIU) on submitting a Suspicious Activity Report (SAR) within the regulated sector. This provides additional guidance on • the type of information which the NCA finds useful in a SAR and • other practical issues relating to SAR submission http://www.nationalcrimeagency.gov.uk/publications/116-submitting-a-sar-within-the-regulated-sector/file

The National Crime Agency (NCA) has issued guidance on submitting a suspicious activity report (SAR). The report contains an overview of SAR Online, the web based system by which SARs can be submitted to the NCA and what information should be included in the SAR: • reasons for suspicion; • details of the subject; and […]

The Serious Organised Crime Agency (SOCA) has published revised guidance  on submitting a Suspicious Activity Report (SAR). This replaces the ‘Top Ten Tips’ document that was previously available. This new guidance sets out advice and best practice to follow when making a SAR to alert Law Enforcement Agencies that certain activity is in some way […]

The Serious Organised Crime Agency has published a guide on the submission of Suspicious Activity Reports (SARs) within the regulated sector. The document seeks to complement the Money Laundering Regulations in providing advice and guidance on best practice when persons in the regulated sector are required under Part 7 of the Proceeds of Crime Act […]