All businesses with obligations under the Money Laundering Regulations are required to have certain policies and controls in place. Under The Proceeds of Crime Act 2002 (POCA) and The Terrorism Act 2000, such firms are required to report money laundering suspicions via a Suspicious Activity Report (SAR). Where a company has concerns over potential or actual suspicious activities, they should follow their internal Suspicious Activity Reporting Procedures and submit an SAR via the proper channels.
Concerns can involve any legal entity that is (or could potentially be) engaged in, or attempting, money laundering, terrorist financing, bribery, fraud and/or tax evasion. Businesses with an AML Supervisory Authority, such as the HMRC or FCA must have controls and procedures for identifying, monitoring and assessing the risks of money laundering and terrorist financing. However, their obligations also include reporting any such concerns or suspicions to the National Crime Agency (NCA) via a Suspicious Activity Report Template.
The internal reporting procedures must ensure that relevant employees can accurately disclose any suspicions and information to a Nominated Officer (NO). The NO is then responsible for investigating the information and activity and where applicable, submitting a Suspicious Activity Report (SAR) via the secure SAR online system on the NCAs website.
Drafting a template for Suspicious Activity Reporting Procedures is fairly straightforward and should consist of the rules and regulations found in the Money Laundering Regulations as well as those requirements set out in the POCA and Terrorism Act. The procedures should include the process for reporting suspicions to the NO/MLRO and how the appointed person then deals with such information. The SAR procedures should also document how to report and submit a Suspicious Activity Report and what timeframes and deadlines apply.
Here at Know Your Compliance Limited, we have been providing businesses with regulatory policies, controls and procedures for over 10 years. With more than 8500 organisations using our templates, documents and toolkits we are the UK’s leader in regulatory template provision. You can purchase our Suspicious Activity Reporting Procedures Template as a standalone document or compare the AML policy template bundles which include the SAR products.