When carrying out your money laundering checks, there may come a time when you find activity that you deem to be suspicious.
If these suspicions could be linked to money laundering or terrorist financing, they must be reported to law enforcement. But when do these need to be reported, and how do you do it?
When should you look at making a report?
There is no concrete answer to what activity you deem to be suspicious, but as a rule of thumb, it’s anything that’s unusual for your business, for example:
- A customer tries to make a large cash payment
- The customer request was unusual and didn’t seem to make sense for what you know about them
- The transaction does not make sense commercially
Every business is different, and suspicious transactions may look different depending on how your business operates and the type of customers you serve.
If your employees become aware of a suspicious transaction, they need to report it to the nominated officer within your business. It’s then up to the nominated officer to decide whether to disclose the incident to the National Crime Agency.
If it’s not practical or safe to suspend the transaction, the report should be made as soon as possible after completing the transaction.
Reports to the National Crime Agency are carried out through Suspicious Activity Reports (SARs).
Suspicious Activity Reports (SARs)
The National Crime Agency provides a portal through which you can complete SARs. SARs can provide an opportunity to stop crime and potentially uncover criminality that needs further investigation.
Through SARs, you can provide information such as contact details, alias identities, bank account details and any other known assets that could lead to an investigation being launched, or add information to an ongoing investigation.
Who can make a SAR?
If you are working in the regulated sector and suspect that a person is engaged in, or attempting to, launder money or finance terrorism, then you need to make a report.
If you’re not in a regulated sector, you may still have an obligation to make a report if you have ‘knowledge’ or a ‘suspicion’ of money laundering. You may be committing an offence if you do not make a report.
Submitting a SAR protects you and your business from the risk of money laundering.
Making a SAR
The easiest way to make a SAR is through the SAR Portal. The portal allows for instant reporting, acknowledgement, and provides you with a reference number (manual reports do not receive acknowledgement or a reference number).
Before you can use the portal, you need to register, allowing you to instantly make a report.
The quality of the information you provide within the SAR can affect the decision to investigate or not. Even if it seems irrelevant, including as much detail as possible can help the investigative process.
Once you’ve been given a reference, don’t forget to record the SAR in your ML Verify account, too.