NCA SARs Regime: Suspicious Activity Reports (SARs) and Defence Against Money Laundering (DAML)
- Issuing authority
- UK Financial Intelligence Unit (UKFIU), National Crime Agency (NCA)
- Effective date
- Operates under the Proceeds of Crime Act 2002 (POCA). The SARs Reform Programme is continuing to modernise the UK's SAR reporting system.
- Scope
- United Kingdom
Key requirements
How regulated firms report suspicions to the NCA's UK Financial Intelligence Unit. Two types: regular SARs (you've spotted something suspicious) and DAMLs - Defence Against Money Laundering reports (you want to do a transaction but suspect it might involve criminal property, so you ask NCA's permission). The SARs Reform Programme is modernising the system with a new IT platform replacing the current SAR Online portal.
Quick Summary
The SARs Regime explains how businesses and individuals report suspected money laundering or terrorist financing to the UK's Financial Intelligence Unit (UKFIU). It also explains when firms should submit a Defence Against Money Laundering (DAML) request if they need permission to continue with a transaction they suspect may involve criminal property.
What is it?
A reporting system for suspected money laundering. If someone working in the regulated sector knows or suspects that money laundering is taking place, they may need to submit a Suspicious Activity Report (SAR) to the UKFIU. In some situations, a firm may also need to request a Defence Against Money Laundering (DAML) before carrying out a transaction that could involve criminal property.
Who does it apply to?
- Banks
- Payment institutions
- Electronic money institutions
- Cryptoasset businesses
- Lawyers
- Accountants
- Estate agents
- Trust and company service providers
- AML analysts
- Money Laundering Reporting Officers (MLROs)
- Other businesses in the regulated sector
Why does it matter?
Submitting SARs helps law enforcement identify criminal activity, investigate financial crime, and recover the proceeds of crime. For firms, understanding when to submit a SAR or request a DAML is an important part of meeting their legal obligations under the Proceeds of Crime Act 2002.
What should firms do?
- Train staff to recognise and escalate suspicious activity.
- Submit a Suspicious Activity Report (SAR) where required under the law.
- Consider whether a Defence Against Money Laundering (DAML) request is needed before completing a transaction involving suspected criminal property.
- Keep clear records of internal decisions and SAR submissions.
- Protect the confidentiality of SARs and avoid tipping off customers.
- Monitor updates to UKFIU guidance and improvements to the SAR reporting system.
AboutAML Breakdown
A Suspicious Activity Report (SAR) simply tells the UKFIU that you know or suspect money laundering or terrorist financing. Most SARs are intelligence reports that help law enforcement identify patterns of criminal activity. A Defence Against Money Laundering (DAML) request is different. If a firm wants to carry out a transaction but believes it may involve criminal property, it may need to request a DAML from the NCA before proceeding. This gives the NCA an opportunity to object to the transaction within the statutory notice period. Understanding the difference between a standard SAR and a DAML request is one of the most important concepts for anyone working in AML