Suspicious Action Letters (SARs) should be submitted to the UK Banking Intelligence Unit (UKFIU) to accommodate intelligence if you know, suspect, or accept reasonable area for alive or suspecting, that a actuality is affianced in, or attempting, money bed-making or agitator financing. It is estimated that £90bn of bent gain are apple-pie anniversary year.
SAR intelligence has been alive in preventing and abolition crimes such as biologic and animal trafficking and adolescent exploitation, allegorical cardinal blackmail assessments and accouterment intelligence that may be of admonition at some point in the future. However, for SARs to be of amount they charge to accommodate as abundant accordant admonition as possible.
We’ve asked the Institute of Banking Accountants for admonition on how to abide a acceptable affection SAR.
Making a acceptable report
SARs should be submitted online via the National Abomination Agency (NCA) website. Helpfully, there is a arrangement for the Accountancy sector, but you ultimately charge to awning the what, who, why, when, how, and area of the crime, while befitting it as blunt as possible.
Delivering a affection address includes:
It is capital to bethink that angled off is illegal. Angled off relates to advice SAR admonition alfresco your organisation that may ageism the analysis by law enforcement.
Playing your part
For accountants affianced in accessible practice, Apprehensive Action Letters are anointed as allotment of your allowable responsibilities in The Money Laundering, Agitator Financing, and Transfer of Funds (Information on the Payer) Regulations 2017, as adapted in 2019. It helps to assure your business from the accident of bed-making the gain of crime, and submitted affirmation is kept confidential.
SARs present a key befalling for accountants to booty an alive role in the apprehension and blockage of bread-and-butter crimes. The letters are acclimated by UKFIU, which is allotment of the NCA, to admonition analyze austere organised abomination threats and forms of fraud, as able-bodied as acknowledging HMRC to abate tax and adulterous costs risks. Accountants charge be active for abeyant money laundering, as authentic in allotment 7 of the Gain of Abomination Act 2022, or agitator financing, as set out in allotment 3 of the Terrorism Act 2000.
Within your organisation, you should accept a nominated actuality for appointment SARs, or a Money Bed-making Advertisement Officer (MLRO). You should additionally abutment your added aggregation with training on how to analyze abeyant risks, what admonition is appropriate to accomplish a submission, and back they should access your MLRO.
When to accomplish an SAR?
The key back free whether you should abide an SAR is to authorize whether there is knowledge, suspicion, or reasonable area for alive or apprehensive money bed-making or agitator financing. The catchy allotment is suspicion, which is authentic as back “you anticipate there’s a possibility, which is added than fanciful, that the accordant actuality exists”. A “vague activity of unease” will not suffice.
The MLRO, charge again booty a appearance as to whether an SAR should be submitted to the NCA. It is reasonable for your MLRO to ask questions about the apropos actuality raised, and to analysis accordant admonition and calm affirmation to abutment their judgement. Due activity is of advance a requirement, but the accountability for an analysis avalanche to the UKFIU already a address has been submitted and there is no claim for your MLRO to undertake an all-encompassing analysis themselves.
The MLRO should not abide a SAR to the NCA if:
One final point, the SAR administration is not a avenue to address abomination or affairs assuming an actual accident to others, and there may be a charge to accomplish letters to added authorities.
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