What is a Suspicious Activity Report (SAR)?
A suspicious activity report (SAR) is the mechanism by which a regulated firm informs the authorities that it knows or suspects money laundering or terrorist financing. Filing a SAR is one of the core obligations of the AML framework, alongside customer due diligence.
Who files and where
- In the UK: SARs are filed to the UK Financial Intelligence Unit within the National Crime Agency (NCA). The reporting obligation sits alongside the Proceeds of Crime Act 2002 and the Money Laundering Regulations 2017.
- In Poland and the EU: reports go to the national financial intelligence unit, in Poland the General Inspector of Financial Information (GIIF).
When to report
The trigger is suspicion, not a specific amount. There is no minimum threshold:
- if you know or suspect money laundering or terrorist financing, you must report it
- some regimes also require reporting of certain transactions above a threshold, but that is separate from the suspicion-based SAR
Timing matters. In practice, firms report promptly and, where a transaction is involved, before it proceeds unless this is not possible.
Tipping off
Once a SAR is filed, it is a criminal offence to tell the customer that a report has been made, or that an investigation may follow. This is known as tipping off, and it is why SAR handling is tightly controlled inside a firm.
Keeping it auditable
A SAR is the tip of the process. Behind it sit screening, monitoring and a documented decision trail. Firms that monitor customers continuously and keep their records current are better placed to identify suspicious activity early. Hyperflow supports that monitoring through its API.