UK’s FIU publishes August guide on SAR submissions

 The UK Financial Intelligence Unit (UKFIU) has published its August guide on how suspicious activity report (SAR) intelligence is being used by law enforcement.

• https://nationalcrimeagency.gov.uk/who-we-are/publications/567-sars-reporter-booklet-august-2021/file

The report aims to demonstrate SAR filing best practices and show what actions are taken in response to SARs. 

Commenting on the guide’s publication Vince O’Brien, head of the UKFIU, said:

• “With this publication, we aim to provide a snapshot of some of the excellent examples we receive highlighting the work of law enforcement agencies in utilizing SAR intelligence to initiate investigations and informing existing ones.”
• SARs “have been instrumental in identifying sex offenders, fraud victims, murder suspects, missing persons, people traffickers, fugitives and terrorist financing.” 

The report highlights a number of recent real-world case studies involving SARs, including:

• An individual being investigated for money laundering offences who had access to false identity documents and several bank accounts with credit balances. SARs alerted officials to the subject’s attempts to open bank accounts in false names. The investigation revealed a web of bank accounts, with amounts exceeding £200,000 moving through the accounts.
• A customer who moved significant funds from a business account into a personal account alongside a pattern of irregular, high volume cash deposits. Deposits were also being withdrawn on the same day they were deposited, raising laundering concerns. An account freezing order was secured for assets worth over £150,000. 
• Multiple SARs uncovered a so-called ‘romance scam’ in which a subject defrauded elderly victims. This included over £150,000 from one victim alone. The money was collected in a number of associate accounts before being moved into the subject’s account. 

UKFIU receives over 570,000 SARs a year.

The number filed in 2019-20 was 264 per cent higher than in 2018-19. However, the overwhelming majority – around 75 per cent – still come from banks. There has been concern that AML/CFT regulated sectors such as accountancy, law, gaming and estate agencies make up a small proportion of the number of SARs filed. Reports like this one showing the impact of SARs on the wider public will be designed to promote their importance, encouraging both higher levels of reporting and a lack of complacency among firms not currently in the regulatory or media spotlight. 

The National Crime Agency (NCA) has also argued that some SARs are of low quality or are unnecessary, calling for deeper reform of the system.

• https://www.ft.com/content/e00ef09a-0f1e-4678-bd0f-fbb405935f97

This came several years after the Financial Action Task Force’s (FATF) 2018 mutual evaluation of the UK, in which it called for reform of the UK’s SARs regime. In response to that review, the Home Office launched a ‘SARs transformation program.’

• https://www.macfarlanes.com/what-we-think/in-depth/2020/reforming-sars-reflections-on-the-reform-programme/