Category: Compliance & AML · Reviewed by Simon Temme, Account Executive · Last reviewed June 2026
A statutory report of suspected money laundering, terrorist financing or other proceeds-of-crime activity submitted to the UK Financial Intelligence Unit at the National Crime Agency under the Proceeds of Crime Act 2002 and Terrorism Act 2000.
A Suspicious Activity Report (SAR) is the formal mechanism by which a regulated firm (or any individual) reports knowledge or suspicion of money laundering, terrorist financing, or other proceeds-of-crime activity to the National Crime Agency’s UK Financial Intelligence Unit (UKFIU). Submitting a SAR provides a statutory defence against an offence of dealing with criminal property; failure to report (where required) is itself an offence.
Proceeds of Crime Act 2002 (POCA), sections 330 (failure to disclose — regulated sector), 331 (failure to disclose — nominated officers), 332 (failure to disclose — other nominated officers), 338 (authorised disclosures), 333A–E (tipping off). Terrorism Act 2000, sections 19 (disclosure of information), 21A (failure to disclose — regulated sector), 21D (tipping off).
A firm’s staff report internal suspicions to the firm’s MLRO. The MLRO investigates and, where the threshold of suspicion is met, submits a SAR via the SAR Online portal. SARs include the customer details, the suspected activity, the supporting evidence, and any DAML (Defence Against Money Laundering) request seeking consent to proceed with a transaction. The NCA has 7 working days to respond to a DAML; if no notice is given within that period, the firm may proceed unless a Notice of Refusal is issued, in which case a moratorium period of up to 31 days applies.
Tipping off offences prohibit disclosing the SAR to the subject or anyone who might prejudice an investigation. The Economic Crime and Corporate Transparency Act 2023 introduced reforms to the SARs regime — including new powers to share information among regulated firms and changes to defence provisions. The threshold is suspicion, not certainty — suspicion has been interpreted by the courts as a possibility, more than fanciful but less than firm belief, of money laundering.
A staff member at Apex notices that a commercial customer’s premium payment has been made from a third-party bank account in a high-risk jurisdiction inconsistent with the customer profile. The staff member reports internally. The MLRO investigates and either dismisses the concern (with documented rationale) or files a SAR via the SAR Online portal with a DAML request if continuing with the transaction.
Proceeds of Crime Act 2002, sections 330, 331, 332, 333A–E, 338. Terrorism Act 2000, sections 19, 21A, 21D. Economic Crime and Corporate Transparency Act 2023. National Crime Agency SAR Online guidance.
By Matt Bartlett, Director, on 2026-06-11.
This entry is part of the Apex Insurance Wiki. Last reviewed by Matt Bartlett on 2026-06-11. Apex Insurance Brokers Limited, FCA FRN 724952, Companies House 07014570. Not regulated advice — consult your broker on your specific position.
Apex Insurance Brokers serves UK professional services firms and commercial businesses. Call 0117 325 0027, email hello@apexinsurancebrokers.co.uk, or request a quotation.
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