How a suspicious activity report works
A monitoring alert, a failed identity check or a member of staff raises a concern. The concern goes to the firm's nominated officer, often called the money laundering reporting officer, who decides whether there is knowledge or suspicion and files the report.
The customer is not told. Disclosing that a report has been made is the offence of tipping off in the UK (Proceeds of Crime Act 2002, section 333A), and is prohibited in the EU (Directive (EU) 2015/849, Article 39).
The rules in the UK, the EU and the US
- UK: a person in the regulated sector who knows or suspects money laundering, or has reasonable grounds to, discloses it as soon as is practicable (Proceeds of Crime Act 2002, section 330).
- UK: reports go to the UK Financial Intelligence Unit, part of the National Crime Agency.
- UK: a firm may ask for consent to carry out a suspect transaction, and is treated as having it if no refusal arrives within seven working days (section 335).
- EU: firms promptly inform the financial intelligence unit of their Member State, whatever the amount, and attempted transactions are reported too (Directive (EU) 2015/849, Article 33).
- US: a bank files with FinCEN within 30 calendar days of first detecting the facts, for transactions of at least $5,000 (31 CFR 1020.320).
Why suspicious activity reports matter to a product
Reporting needs plumbing: case management that keeps the evidence, a way to hold or release a payment while a report is pending, and access controls so that few staff can see that a report exists. A company under a partner's licence escalates to the partner, whose officer files.
Failing to report is itself an offence for people in the UK regulated sector. Firms therefore train staff to escalate, and record why a concern was or was not reported.
SAR, STR or crime report?
- Suspicious transaction report
- The EU's name, and the FATF's, for the same filing. The trigger is the same: knowledge or suspicion.
- Crime report
- A report to the police. The National Crime Agency states that SARs are not crime reports, and do not replace one.
- Threshold report
- Filed for transactions above a set size, such as large cash payments, whether or not anything looks wrong. A SAR starts from suspicion.
Where a suspicious activity report shows up in a platform
Modules that do the work
- Compliance reportingTransaction monitoring, the Travel Rule and regulatory reports, ready for your regulator.
- KYC / AMLIdentity checks, screening and ongoing monitoring, with the verification provider you choose.
- BackofficeOne console to run the platform: customers, money, risk, content and staff permissions.
- Fraud & riskReal-time fraud scoring, limits and case management, with the risk engines you already trust.
Platforms that need it
Where it is written
The laws and standards this page's facts come from.
- Proceeds of Crime Act 2002, Part 7: money laundering (legislation.gov.uk)
- National Crime Agency, Suspicious Activity Reports
- Directive (EU) 2015/849, the Anti-Money Laundering Directive, consolidated (EUR-Lex)
- 31 CFR 1020.320, Reports by banks of suspicious transactions (eCFR)
General information, not legal advice: what applies to you depends on your services and your market.