If you suspect money laundering at work, you do not call the police, and you must not tell the person involved. You report it through a Suspicious Activity Report, or SAR: a confidential disclosure to the National Crime Agency (NCA) made through its secure SAR Portal. In the regulated sector you usually report internally first, to your firm’s nominated officer, who decides whether to pass it to the NCA. Warning your customer that a report has been made is a separate criminal offence called “tipping off”. Getting the process right matters, because failing to report a suspicion can itself carry up to five years in prison.
At a glance: Nexis CPD’s £9 Anti Money Laundering (AML) Awareness course covers how to spot the warning signs, your reporting duties and how a SAR is made. It is CPD accredited and 100% online with a verifiable e-certificate, and any three courses cost £18. It is awareness training, not a regulated or ICA-level qualification.
What is a suspicious activity report (SAR)?
A suspicious activity report is a formal disclosure telling the UK’s financial intelligence authorities that you know or suspect, or have reasonable grounds to know or suspect, that someone is involved in money laundering or terrorist financing. It is the main way that information about suspected economic crime reaches law enforcement. SARs are received, stored and analysed by the UK Financial Intelligence Unit (UKFIU), which sits inside the National Crime Agency and, in its own words, “has sole national responsibility for receiving, analysing and disseminating SARs in the United Kingdom”.
The scale is larger than most people assume. The NCA says the UKFIU receives more than 850,000 SARs a year and holds a database of over 4.5 million reports. Each one is a piece of intelligence that can be matched against other reports, linked to live investigations, or used to freeze and recover criminal funds. A single well-written SAR from a conveyancing solicitor or an estate agent can be the thread that unravels a much larger laundering network.
There are two broad situations in which a SAR is made, and the distinction matters a great deal:
- A “required disclosure”. You simply suspect money laundering and are telling the authorities, as the law requires. This does not stop you carrying on with the transaction.
- A “defence against money laundering” (DAML) request. You want to carry out an act that might itself be a money laundering offence, such as transferring suspect funds, and you are asking the NCA for consent, which the law calls “appropriate consent”. This type of SAR can stop a transaction in its tracks.
Both are submitted through the same channel, but the consequences and the timing are different, and we explain the DAML route in detail below.
Who has to submit a SAR?
Here is the point that surprises people: anyone can make a SAR, but people working in the “regulated sector” have a legal duty to. The regulated sector is defined in the Proceeds of Crime Act 2002 and covers financial institutions, accountants, auditors, tax advisers, legal professionals doing certain work, estate and letting agents, high value dealers, casinos, trust and company service providers and others.
Under section 330 of the Proceeds of Crime Act 2002 (POCA), a person in the regulated sector commits an offence if they know or suspect, or have reasonable grounds to know or suspect, that another person is engaged in money laundering, the information came to them in the course of business in the regulated sector, and they do not make the required disclosure “as soon as is practicable”. The threshold is important. The duty is not triggered only by firm knowledge; it also bites where there are objective “reasonable grounds” to suspect, even if you personally failed to connect the dots. That is why training matters: you cannot report what you have not been taught to notice.
In most regulated firms you do not report directly to the NCA. You report internally to your firm’s nominated officer, often also called the Money Laundering Reporting Officer (MLRO). The Money Laundering Regulations 2017 require firms above a certain size to appoint such a person. The nominated officer considers the internal report, decides whether the suspicion is well-founded, and if so submits the external SAR to the NCA. Making your internal report to the nominated officer is what discharges your personal legal duty under section 330. Our guide to AML training requirements explains who needs training and how often.
Outside the regulated sector there is no general legal duty to report, but it is still an offence under sections 327 to 329 of POCA to deal with criminal property yourself, so making a voluntary SAR and seeking a defence can protect you.
Which businesses are supervised for anti-money laundering?
Every regulated business must be supervised for AML purposes by a named supervisor. Which supervisor depends on the sector. The Financial Conduct Authority supervises banks and most financial services firms. Professional bodies supervise many solicitors and accountants. HMRC is the supervisor for the sectors that nobody else covers, and its list of supervised sectors includes:
- money service businesses not supervised by the FCA;
- high value dealers accepting cash of €10,000 or more;
- trust or company service providers not otherwise supervised;
- accountancy service providers not supervised by a professional body;
- estate agency businesses;
- letting agency businesses handling rents of €10,000 or more a month;
- art market participants dealing in works of €10,000 or more;
- bill payment and telecoms, digital and IT payment service providers not supervised by the FCA.
This is why AML sells so hard to estate agents and accountants: both are squarely within the HMRC-supervised population and must register, train staff, carry out customer due diligence and report suspicions. If you are an estate or letting agent, our note on CPD requirements for estate agents sets out the wider training expectations for the role.
How do you submit a SAR to the NCA?
SARs are submitted electronically through the NCA’s SAR Portal. The NCA describes the portal as “the most secure and efficient way to submit a SAR”, it is available 24 hours a day, and you receive an acknowledgement and a unique reference number after submission. The older bulk and paper routes have largely been retired in favour of the portal.
A good SAR is not a tick-box exercise; it is an intelligence product. The UKFIU asks reporters to make the reason for suspicion clear and to structure the information so an analyst can act on it quickly. In practice that means covering:
- Who. Full identifying details of the subject or subjects: names, dates of birth, addresses, account numbers, company numbers and any identifiers you hold from your customer due diligence.
- What. A clear, factual description of the activity and the specific reason it looks suspicious, written in plain English, not jargon.
- Where and when. Dates, amounts, locations and the movement of funds or property.
- Why. What first prompted the suspicion, and how it fits what you know about the customer.
The NCA also runs a system of “glossary codes” and “reporter reference” fields that let reporters flag particular threats, such as vulnerable persons or specific crime types, so that reports can be prioritised. If your SAR is a DAML request, you must say so clearly and describe exactly the act for which you want a defence; a vague request risks being treated as an ordinary report with no consent given.
Before any of this, accurate customer records make a SAR far easier to write. Strong customer due diligence at the start of a relationship gives you the identifying detail a useful report depends on.
What is a DAML request and the moratorium period?
This is where SARs stop being paperwork and start affecting real transactions. If you are about to do something that could make you complicit in laundering, such as completing a property purchase with funds you suspect are criminal, you can seek a defence against money laundering by submitting a DAML request. You must then wait before acting.
The timeline is set by POCA and is precise:
- The notice period: 7 working days. This begins on the first working day after you make the disclosure. If the NCA does not refuse consent within those 7 working days, you are treated as having consent and can proceed.
- The moratorium period: 31 calendar days. If the NCA refuses consent within the notice period, a moratorium period of 31 days begins on the day consent is refused. During this time you must not carry out the act. This gives law enforcement a window to investigate, restrain funds or take other action.
- Extensions up to a maximum of 186 days. The Criminal Finances Act 2017 inserted section 336A into POCA, letting a court extend the moratorium period by up to 31 days at a time. The court “may not grant a further extension” if the total extension would exceed 186 days beyond the original 31-day period.
In the great majority of cases the NCA does not refuse consent and the transaction proceeds after 7 working days. But the possibility of a 31-day freeze, extendable to roughly six months, is a powerful reason to submit a DAML request early rather than on completion day. Submitting one does not label you as the wrongdoer; it protects you from prosecution for the principal money laundering offences if you then act with consent.
What is “tipping off” and why does it matter?
Confidentiality is the part of the SAR regime people most often get wrong. Once a disclosure has been or is going to be made, you must not tell the subject or anyone else in a way that could prejudice an investigation. This is the offence of “tipping off”. Under section 333A of POCA, a person in the regulated sector commits an offence if they disclose that a SAR has been made and that disclosure is likely to prejudice any resulting investigation. The maximum penalty is severe: on conviction on indictment, “imprisonment for a term not exceeding two years, or to a fine, or to both”.
A separate offence under section 342 of POCA covers “prejudicing an investigation” more broadly, for example destroying or falsifying documents once you know an investigation is under way. The practical rules for front-line staff are simple:
- Do not tell the customer you are concerned, that a report has been made, or why a transaction is delayed, in any way that reveals a SAR.
- Do not discuss the report with colleagues who do not need to know.
- Route everything through your nominated officer and follow their instructions.
- If a customer asks why something is taking time, give a neutral, truthful answer that does not reveal the SAR, and check with your nominated officer if unsure.
There are limited statutory exceptions, for example disclosures within the same group or between certain professionals for the purpose of preventing an offence, but front-line staff should never rely on these without guidance. When in doubt, say nothing and ask the nominated officer.
What happens after you submit a SAR?
Once a SAR reaches the UKFIU, it is entered into the national database and made available to law enforcement and other authorised end users, such as police forces, HMRC and the intelligence services. Analysts look for links to existing investigations and emerging threats. A single SAR might sit quietly as one data point, or it might trigger immediate action.
What you will usually not receive is feedback. Because SARs feed live and often sensitive investigations, reporters are rarely told what came of a report. That silence is not a sign the report was ignored; it is a feature of the system. The exception is a DAML request, where you will be told whether consent is given or refused within the notice period. The NCA publishes an annual SARs report with aggregate figures and case studies, and these show that information from the regulated sector routinely supports asset recovery, safeguarding of vulnerable people and major criminal cases.
Your own records matter after submission too. You should keep a copy of the SAR and the surrounding decision-making securely, limit who can see it, and retain it in line with your firm’s policy and the Money Laundering Regulations. SAR records contain sensitive personal data, so they must be handled in line with UK data protection law as well.
What are the penalties for not reporting?
The penalties under POCA are what give the SAR regime its teeth, and they fall into two tiers.
First, the principal money laundering offences. Under sections 327 to 329 of POCA, it is an offence to conceal, disguise, convert, transfer or remove criminal property (section 327), to enter into or become concerned in an arrangement that facilitates the use of criminal property (section 328), or to acquire, use or possess criminal property (section 329). Section 334 sets the maximum penalty for these at “imprisonment for a term not exceeding 14 years or to a fine or to both” on conviction on indictment. Making a timely SAR and obtaining a defence is what protects a business from these offences when it has to handle suspect funds.
Second, the failure to report offences. Section 330 (failure to disclose in the regulated sector), section 331 (failure by a nominated officer) and section 332 carry, under section 334, a maximum of “imprisonment for a term not exceeding five years or to a fine or to both” on indictment. In other words, in the regulated sector you can be prosecuted not for laundering money, but simply for failing to report a suspicion you should have reported. Tipping off, as noted above, carries up to two years.
On top of the criminal law, supervisors such as the FCA and HMRC can impose their own civil penalties and fines for AML failures, and professional bodies can take disciplinary action. The reputational cost of an AML failing, for a firm whose business depends on trust, often exceeds the fine.
Does a SAR also cover terrorist financing?
Yes. The SAR regime is the single channel for two separate legal duties. Money laundering reporting flows from POCA. Terrorist financing reporting flows from the Terrorism Act 2000, which contains its own disclosure offence for the regulated sector. In practice both are submitted through the same NCA SAR Portal, and a reporter who suspects funds are linked to terrorism should flag this clearly so the report is routed and prioritised correctly. The thresholds and defences differ slightly between the two regimes, which is another reason to make sure front-line staff can recognise both kinds of risk rather than assuming every concern is “just” money laundering.
How can firms get SAR reporting right?
Getting SARs right is less about legal expertise and more about everyday habits. The firms that do it well tend to share a few features: every member of staff can recognise a warning sign and knows exactly who the nominated officer is; internal reports are made promptly and in writing; the nominated officer applies a consistent, documented test before deciding whether to submit; DAML requests go in early, not at the last minute; and confidentiality is treated as non-negotiable so that tipping off never happens by accident.
Training is the foundation of all of this. A staff member who has never been shown what layering, smurfing or a suspicious source of funds looks like will not form the “reasonable grounds to suspect” that the law expects. For a plain-English grounding in the system as a whole, see our guide to what anti-money laundering is, and remember that bribery and corruption often sit alongside laundering, which our Anti Bribery Awareness course addresses.
Make reporting easy and blame-free. Staff should feel safe raising a concern that turns out to be innocent; the law protects a disclosure made in good faith, and a culture that punishes “false alarms” is a culture that will miss the real thing.
Train your team to spot and report suspicion
Nexis CPD’s Anti Money Laundering (AML) Awareness course gives staff in estate agencies, accountancy practices, legal firms and other regulated businesses the grounding they need to recognise suspicious activity and understand the SAR process, including the roles of the nominated officer and the NCA.
£9 per course. CPD accredited, 100% online, verifiable e-certificate. Pay for 2, get 3 — any 3 courses for £18. It is awareness training to support your firm’s AML programme, not a regulated or ICA-level qualification.
Frequently asked questions
What is a suspicious activity report?
A suspicious activity report (SAR) is a confidential disclosure to the National Crime Agency telling it that you know or suspect, or have reasonable grounds to suspect, that someone is involved in money laundering or terrorist financing. SARs are received and analysed by the UK Financial Intelligence Unit within the NCA, which receives more than 850,000 of them a year.
Who do you report money laundering to in the UK?
You report it to the National Crime Agency through its secure SAR Portal, not to the police directly. In a regulated firm you normally report internally to your nominated officer or MLRO first, and they decide whether to submit the external SAR to the NCA. Anyone can make a SAR, but people in the regulated sector have a legal duty to.
Is it a crime to not report money laundering?
In the regulated sector, yes. Under section 330 of the Proceeds of Crime Act 2002, failing to disclose a suspicion of money laundering when you have knowledge or reasonable grounds to suspect it is a criminal offence, carrying a maximum of five years’ imprisonment on conviction on indictment. The principal money laundering offences under sections 327 to 329 carry up to 14 years.
What is tipping off?
Tipping off is the offence, under section 333A of POCA, of telling the subject or anyone else that a SAR has been made or is planned, where that disclosure is likely to prejudice an investigation. It applies to the regulated sector and carries a maximum of two years’ imprisonment on indictment. Never tell a customer that you have concerns or that a report has been made.
What is a DAML and how long does it take?
A defence against money laundering (DAML) request is a SAR asking the NCA for consent to carry out an act that might otherwise be a money laundering offence. The NCA has a notice period of 7 working days to respond. If it refuses consent, a moratorium period of 31 calendar days begins, during which you must not act, and a court can extend this up to a maximum of 186 days.
Do estate agents and accountants have to report suspicious activity?
Yes. Estate agency businesses, letting agency businesses and accountancy service providers are within the regulated sector and are supervised for AML purposes, with HMRC acting as supervisor where no other body does. They must register, carry out customer due diligence, train staff and report suspicions of money laundering through a SAR.
This article is general information about reporting suspected money laundering in the UK and is not legal advice. Reporting duties depend on your sector and circumstances. For advice on a specific situation, consult your nominated officer, your AML supervisor or a qualified professional, and refer to the current legislation and NCA guidance.