There are around 3.8 million suspicious activity reports (SARs) on the UK’s SARs database. The UK Financial Intelligence Unit (UKFIU) – the body charged with analysing and disseminating information to law enforcement agencies in the UK and overseas – has seen consistently increasing volumes of submissions in recent years, with more than 900,000 reports in the past year alone.
There is little value in holding millions of SARs if they’re written in a way that makes it difficult to validate them
The database provides a wealth of intelligence that would not otherwise be available to the UKFIU’s law enforcement partners and can assist investigations in many parts of the world.
Although the scope and potential of SARs reports is truly massive, there is little value in holding millions of SARs if they’re written in a way that makes it difficult for the UKFIU to validate them or for law enforcement to use them in their investigations.
With this in mind, the UKFIU’s reporter engagement function was set up to ensure that SARs are fit for purpose, with updated guidance issued in January 2023.
Glossary codes are crucial to be able to conduct analysis, and fast-track high-risk or time-sensitive cases
Below are some tips to help reporters to create effective SARs.
Use glossary codes
Glossary codes, which are circulated to SARs reporters, relate to specific threat areas. They are crucial for the UKFIU to be able to conduct analysis, feed intelligence up to senior management teams and fast-track high-risk or time-sensitive cases.
What are SARs?
Suspicious activity reports (SARs) are submitted when there is knowledge or a suspicion that an organisation or individual is engaged in money laundering or terrorist financing. They are not just used in financial investigations; they can be used in any law enforcement investigation.
Anyone can submit a SAR, but people working in the regulated financial services sector are required (under Part 7 of the Proceeds of Crime Act 2002 and the Terrorism Act 2000) to submit a SAR if they receive information that leads them to know or suspect that a person is engaged in, or attempting to engage in, money laundering or terrorist financing.
Include all elements
The UKFIU and wider law enforcement can read hundreds or even thousands of SARs per week. Reporters can facilitate this process by ensuring that all required elements of the Proceeds of Crime Act 2002 (POCA) or Terrorism Act 2000 (TACT) have been met. In doing so, it’s less likely that the UKFIU will have to refer back to the reporter for further information.
Think like an investigator
It’s helpful to put yourself in the shoes of an investigator and consider what information would be useful. For example:
- Account numbers are unique identifiers and searchable by law enforcement.
- If funds are moving overseas, it’s best practice to include the jurisdictions.
- If you are filing a SAR because the police got in touch with you, let us know which police force or unit it was (please do not include any officers’ names) so we can ensure that it is sent to the correct place.
- Consider including other information such as IP addresses for your subject, or advising whether you hold scanned documents such as copies of passports. This will enable investigators to know exactly where to look for the intelligence they require to further their investigation.
More information
There are lots of resources on the UKFIU website, including the ‘Frequently asked questions’ booklet
Read ACCA’s factsheets on how to submit good-quality suspicious activity reports and guidance on anti-money laundering regulations
