Frequently Asked Questions (FAQs)
Below are a number of questions and answers that will assist in guiding you through the process of completing and submitting a Suspicious Activity Report (SAR):
Q. What is a SAR?
A. A Suspicious Activity Report (SAR) is a piece of information which alerts law enforcement that certain customer activity - e.g. the cash purchase of a high-value asset or a series of large out-of-character deposits - is in some way suspicious and might indicate money laundering or terrorist financing.
SARs are a vital weapon in the UK’s armoury to prevent and detect crime, and to protect the integrity and reputation of the UK financial system. SARs can make a contribution to a range of outcomes in relation not just to anti-money laundering and counter-terrorist financing, or even serious organised crime, but to all crime. Such outcomes include building intelligence on criminals and terrorists, crime prevention, criminal convictions and asset recovery.
Q. What are SARs used for?
A. Every SAR can be used many times for many different purposes and all SARs contribute to the prevention and detection of crime. They can lead law enforcement to an otherwise undiscovered criminal asset or movement of criminal funds. They can also provide corroboration or added detail to an existing intelligence picture.
SARs may identify the criminality, assets or methods of a burglar or car thief, just as much as a drugs dealer, VAT fraudster or money launderer. That same SAR may also help establish a picture of the vulnerability of a particular sector or product. It may be used in an analysis of suspicious activity before and after a specific event, e.g. a terrorist incident.
Q. Why should I submit a SAR?
A. It is a criminal offence for someone working in the regulated sector to not disclose to either their institution’s ‘Nominated Officer’ (often referred to as a Money Laundering Reporting Officer [MLRO]) or directly to the UKFIU if they know or suspect, or have reasonable grounds for knowing or suspecting, that another person is engaged in money laundering or terrorist financing.
Q. Who submits SARs?
A. The Proceeds of Crime Act 2002 (POCA) and Terrorism Act 2000 (TACT) (569.82 kB PDF) require businesses in the Regulated Sector to report to the UKFIU any suspicions that arise concerning criminal property, money laundering or terrorist financing.
It is an offence for someone working in this sector not to disclose to either their institution’s ‘Nominated Officer’ (often referred to as a Money Laundering Reporting Officer [MLRO]) or directly to the UKFIU if they know or suspect, or have reasonable grounds for knowing or suspecting, that another person is engaged in money laundering or terrorist financing.
Q. Do I have to submit a SAR if I am not in the Regulated Sector?
A. There will be firms or businesses outside the Regulated Sector which may still be conducting an illegal transaction, if suspicion comes to them by way of their trade, business or profession. This could include members of the public. This sector is known as the Non-Regulated Sector.
You may therefore commit an offence if you have knowledge or suspicion of money laundering activity or criminal property and/or do something to assist another in dealing with it, and fail to make a SAR. Submitting a SAR provides a defence against committing a money laundering offence.
The Proceeds of Crime Act 2002 (POCA) allows persons and businesses generally, and not just those in the Regulated Sector, to avail themselves of a defence against money laundering charges by seeking consent of the authorities (via the UKFIU) to conduct a transaction or undertake other activity (a “prohibited act”) about which they have concerns.
Q. When should I submit a SAR?
A. A SAR should be submitted as soon as you have a suspicion or knowledge of money laundering by another person, especially if consent may be required, or at the earliest opportunity.
Q. Can a SAR be submitted after completion of a transaction?
A. Yes. Most of the reports SOCA receives are after the transaction has taken place. An example of this may be that you are not suspicious at the time of the transaction, but information comes in at a later date which makes you suspicious. You would then subsequently make a report. However, if it was a future transaction that was about to take place, then consent should be applied for.
Q. What is consent in relation to SARs?
A. Persons and businesses generally, and not just those in the regulated sectors, may avail themselves of a defence against money laundering charges by seeking, via a SAR, the consent of the SOCA UKFIU to conduct a transaction or undertake other activity about which they have concerns. The legislation gives SOCA seven working days to respond. Should SOCA refuse consent the transaction or activity must not proceed for a further 31 calendar days or, if earlier, until further notified by SOCA.
Further information is available elsewhere on the SOCA website or by calling the SOCA Consent desk, 020 7238 8282, and selecting Option Four from the menu.
Q. How do I submit a SAR?
A. SARs are sent electronically or in hard copy to the UKFIU.
Electronically, they can be submitted by using SAR Online and Bulk SARs Submissions.
SARs can be sent in hard copy using the SOCA Preferred Paper SAR Form, posted to UKFIU, PO Box 8000, London, SE11 5EN. If the report is seeking consent in hard copy it can be faxed to the UKFIU on 020 7238 8286.
We highly recommend you do not, if at all possible, submit on paper. However, if you do, please ensure it is in typed format as detailed above.
Q. What methods can be used to submit a SAR?
A. 1) SAR Online
SAR Online is the UKFIU’s preferred and most practical way of making a SAR and can be used by anyone with internet access, via the link above or elsewhere on the SOCA website. It is a free and secure system, and reports can be made 24 hours a day, seven days a week.
SAR Online enables you to submit a report securely, removing the need to complete, and post or fax, paper-based reports. Reporters are guaranteed an acknowledgement by email, containing a unique reference number, once a report is submitted.
Other benefits of SAR Online include pop-up tool tips on certain pages, an information link providing background relevant to financial reporting, and a Frequently Asked Questions (FAQs) document. SARs can also be marked as ‘private’ to an individual user.
A. 2) Large Volume (Bulk) SARs Submissions
If your organisation frequently submits a large volume of SARs this may be a more convenient and practical facility to use, rather than SAR Online. For more information on this free service please contact the Money.Web support team on 020 7238 2888 o or email moneywebsupport@soca.x.gsi.gov.uk
Those who currently use Encrypted Bulk File Submissions to submit electronic reports should continue to do so. Please do not email completed disclosures without encryption.
A. 3) Paper Submission
For those unable to use SAR Online or Money.Web, the Preferred Paper Form can be downloaded from our Reporting Forms page as a PDF. Acrobat Reader allows completed forms to be printed from your personal computer; however it does not allow completed forms or partially completed forms to be electronically saved.
Alternatively you can obtain forms by contacting the UKFIU SAR Administration and Control department on 020 7238 8282 and selecting Option Two. Details of how to complete this form will be enclosed with the forms sent to you.
Please do not complete the version of the form downloaded from the internet by hand, as the misreading of handwriting increases potential errors when disclosures are keyed onto the SOCA system.
All hard copy reports should be sent to UKFIU, PO Box 8000, London, SE11 5EN. They can also be faxed to 020 7238 8286.
Q. How do I register for SAR Online?
A. Registering is free and SAR Online can be accessed at SAR Online or elsewhere on the SOCA website. To register, a working email account is required. This email address will be your SAR Online user identification and can only be used once - no two users can use the same email address.
The system is designed so that any New User Registration requires the user to register the details of the Reporting Entity they represent (i.e. those persons required by the Proceeds of Crime Act 2002 and the Terrorism Act 2000 to submit SARs). To ensure these details are accurate it is recommended that the registering user be an official responsible for the Anti Money Laundering (AML) compliance within the organisation, such as the Money Laundering Reporting Officer (MLRO), Nominated Officer or similar. The initial SAR Online registration process will take several minutes to complete. It is important to read the explanatory note prior to the initial registration process as this describes the site structure and the steps you must follow.
The SAR Online helpdesk is available 9am to 5pm, Monday to Friday. Please telephone 020 7238 8282 and select Option Three from the menu.
Q. What happens to a SAR once submitted?
A. Upon receipt, SARs are logged on to the United Kingdom Financial Intelligence Unit (UKFIU) SARs database for information evaluation and analysis. The UKFIU analyses SARs to extract strategic and tactical intelligence, and makes all SARs available to law enforcement agencies for investigation (with the exception of certain sensitive SARs).
Q. Will I be told when you have received my SAR?
A. The SAR Online system will allow your business to submit SARs in a secure and efficient manner and send you a prompt electronic acknowledgement,
Q. Will I get feedback on my SAR?
A. The UKFIU believes feedback is a powerful tool for improving the efficiency of the SARs regime, and works with all participants to ensure the right level of meaningful feedback is provided.
If a SAR leads to law enforcement action then it is likely the law enforcement officer will contact the reporter and maintain contact until the case is closed, for example the end of a trial. In some cases law enforcement may wish to act on information contained in a SAR, but for operational reasons may not contact the reporter.
The UKFIU will provide feedback on the degree to which SARs have been used - both by SOCA and other users - but that will usually be in relation to SARs as a whole and not each individual SAR. In some circumstances the UKFIU provides individual businesses with feedback in relation to the SARs they provide.
Q. May I inform a client/customer that I have made a report?
A. You must not say anything to your client/customer which may lead to an investigation being prejudiced. If that provides you with particular difficulties you can seek guidance from SOCA. In certain cases a form of words can be agreed that may overcome problems.
Q. Is my SAR confidential?
A. All users of SARs adhere to specific guidelines to protect the confidentiality of SARs. Once a SAR is received by the UKFIU it is held on a secure database with strictly limited access to appropriate law enforcement and government agency staff. The information is always held in the strictest confidence.
Q. Is the information contained in the SAR I submit held securely?
A. All users of SARs adhere to specific guidelines to protect the confidentiality of SARs. Once a SAR is received by SOCA it is held on a secure database with strictly limited access to appropriate law enforcement and government agency staff. THE INFORMATION IS ALWAYS HELD IN THE STRICTEST CONFIDENCE. If in the unlikely event you are made aware that any confidentiality may have been breached, you should contact SOCA on Freephone 0800 234 6657, 9am-5pm, Monday to Friday.
Q. Are individuals entitled to know whether they are on the SARs database?
A. The Data Protection Act (DPA) 1998 allows for any member of the public to request access to their personal data under Section 7 of the Act. SOCA has an established process for dealing with such enquiries, although the individual responses may be subject to statutory exemptions.
Q. Is the Information Commissioner responsible for monitoring the entries in the SARs database?
A. The Proceeds of Crime Act 2002, the Terrorism Act 2000 and the Data Protection Act 1998 do not specify a role for the Information Commissioner's Office (ICO) in respect of the SARs regime. However, as with all personal data held, the ICO has jurisdiction to ensure that the statutory requirements of the DPA are followed by SOCA.
Q. Do all end users of SARs have equal rights of online access to the SARs database?
A. SARs that are considered particularly sensitive, for example that relate to terrorism and corruption, are not accessible by the full range of end users.
A third category – proliferation finance reports - is also unavailable to all end users. However these are not SARs under the Proceeds of Crime Act 2002 or the Terrorism Act 2000.
Q. What records are kept of those accessing the SARs database?
A. The SARs database allows SOCA to extract information about access of the data by end users. SOCA undertakes some analysis of this usage and will retain the results of this for the period of time for which the information has operational value.