What is a suspicious activity report (SAR)?

In short

A suspicious activity report (SAR) is the report a firm sends to its country's financial intelligence unit when it knows or suspects that funds are the proceeds of crime or are linked to terrorist financing. Suspicious activity report is the name used in the UK and the US, and EU law calls the same filing a suspicious transaction report (STR).

Also called
SAR, Suspicious transaction report, STR
Family
Accounts, licences and compliance
Facts checked

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

Platforms that need it

Where it is written

The laws and standards this page's facts come from.

General information, not legal advice: what applies to you depends on your services and your market.

Every term

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