With many new data fields to complete, the enhanced quality of submissions will provide much better intelligence to the UK FIU, law enforcement agencies and government departments in their fight against organised crime.
It’s a move that underlines the NCA’s commitment to ramping up the fight against money laundering (ML), terrorist financing (TF) and proliferation financing (PF).
Regulated professionals should never lose sight of the fact that the ability to submit a detailed and accurate SAR to the UK Financial Intelligence Unit (FIU), which sits within the NCA, is one of the key reasons the money laundering regulations have been in place since 2007.
Submitting a SAR provides law enforcement with invaluable information about known or suspected criminal activity that they may not otherwise have access to.
The drive for change
ML, TF and PF are ever-evolving threats that pose significant risks to our national security and financial systems. Criminal bodies and terrorist groups use increasingly sophisticated methods to legitimise their illicit gains or fund their activities. SARs play an essential role in the fight against it by acting as an alert system for potentially suspicious activities.
Faced with evolving risks and technological advancements, there’s an imminent need for a more secure, comprehensive and user-friendly system to report suspicious activity. Not to mention one that produces a report with as many details as possible for law enforcement.
By enhancing the SAR reporting process, the new portal will be instrumental in improving the quality and detail of SAR submissions. Submitting a SAR protects you, your business and you employees from the risk of laundering the proceeds of crime, terrorist financing or proliferation financing. The information you supply could play an important part in combatting criminal activity. It may be the missing part of a much bigger jigsaw puzzle you were not aware of.
The AMLCC SAR portal for making and storing internal Suspicious Activity Reports has been fully updated to align with the new NCA portal and will also be available from Monday 18th September. In making these updates, we’ve been able to appreciate the extent to which the SAR questions have evolved. Please don’t forget that internal SAR reports must be made and kept as a key part of your business’ AML records so the MLRO, as well as the employees, should make internal SARs prior to the decision to report to the NCA.
You need to submit a SAR using the NCA secure online portal. It gives you an instant acknowledgement with a reference number. This portal is available via the ‘reporting SARs’ link in the top right hand corner of the NCA website.
Do you have the right information?
There’s an enhanced range of data fields designed to strengthen the quality of your SAR. The important thing is that you already have the correct information on file.
Accessing all this information won’t be an issue if you’ve already completed all your AML obligations and kept records of your work. Remember: the clearer and more comprehensive the information in your SAR, the more useful and actionable that report is.
You’ll need details like these:
Subjects involved: Reporters will need to provide more detailed information about the individuals or organisations involved in suspicious activities. These includes passport details, national insurance number, driving licence number, tax reference, IP address and so on if you have these details available to you.
Suspicious activity details: This is one of the main upgrades. The portal provides free text boxes to provide all known details of the alleged activity. It’s essential to explain why the activity is deemed suspicious and provide the groundwork for potential investigations.
Glossary codes: The new portal provides six groups of glossary codes:
- Vulnerable people
- High risk individuals
- High risk predicate offences
- Money laundering typology
- Economic predicate offences
- National interests
A SAR can have several codes that should be used to categorise your suspicion. Their use is good practice and crucial for enabling the FIU and wider law enforcement to identify money laundering trends, and high risk cases for development and action.
Defence against money laundering (DAML) or terrorist financing (DATF): As you may be aware, where you suspect or know that property is criminal, or suspect or believe that something is or may be terrorist property, and where you intend to carry out an activity which you anticipate could result in committing a principal money laundering or terrorist financing offence, you may request a criminal defence from the NCA in relation to that intended activity. For example, transferring funds from a client account which you know or suspect to be the proceeds of crime.
The new SAR portal allows you to request a DAML or a DATF rather than having to apply separately as before.
Looking to the future
The introduction of the new SAR portal marks an important step forward in the war against illicit finance. However, the challenge does not end with the adoption of a new system.
For the new portal to achieve its aims, it’s also critical for AML regulated firms to maintain a culture of compliance, so that every employee is able to spot suspicious activities and fully complete an internal SAR. The MLRO in turn needs to know when it’s appropriate to make an external report.
Launching a new portal is a solid step forward. In time, its true effectiveness in strengthening the SAR system — and hence, the fight against ML, TF and PF — will be seen.
Richard Simms is Managing Director of AMLCC.