From Suspicion to Submission: How to File a SAR the Right Way

Submitting a Suspicious Activity Report (SAR) is a core legal obligation for regulated firms and professionals. However, the UK Financial Intelligence Unit (UKFIU) makes clear that poorly structured or incomplete SARs reduce intelligence value and may delay or prevent effective law enforcement action.

There are two types of SAR. An Intelligence only SAR and a Defence Against Money Laundering (DAML) SAR, where you require a defence before proceeding with a transaction or activity. The first few steps below apply to both types. Steps 6 and 7 apply to DAML SARs only.

This article sets out a practical, step-by-step approach to submitting SARs in line with NCA guidance.

Step 1: Confirm a SAR is the Correct Reporting Route

SARs are used solely to report knowledge or suspicion of money laundering or terrorist financing under POCA or TACT. They are not crime reports and do not replace police or emergency reporting routes where relevant.

If a matter has already been reported elsewhere, this should be clearly referenced in the SAR.

Step 2: Select the Correct Legislation

You must select:

• POCA for money laundering suspicions
• TACT for terrorist financing suspicions

These are handled by different UKFIU teams. Selecting the wrong legislation can delay dissemination.

If both suspicions exist, two separate SARs must be submitted.

Step 3: Complete All Relevant SAR Portal Fields

Even where fields are marked “optional”, they should be completed if the information is held. Relying solely on free-text fields limits the SAR’s usefulness.

Step 4: Identify All Relevant Parties

SARs should include all available identifying information for the main party and any associated parties. This includes:

• Full names
• Dates of birth
• Addresses
• Nationality
• Account details
• Any information contained in documents you have gathered

Step 5: Write a Clear “Reason for Suspicion”

The “Reason for Suspicion” section should explain:

• Who is involved
• What happened and when
• Why the activity is suspicious
• Any red flag or high-risk indicators, including links to adverse media found online

It should be concise, chronological, and written in plain English. Avoid sector-specific jargon or acronyms — the team at the UKFIU works across all regulated sectors, so tell the story in a way that can be understood without specialist knowledge.

DAML SARs: Additional Steps

The following two steps apply only where you are seeking a Defence Against Money Laundering (DAML). If you are submitting an Intelligence SAR, these steps do not apply.

Step 6: Describe the Criminal or Terrorist Property

You will be asked to specify which money laundering offences you are seeking a DAML for. You may seek a defence for one, two, or all three of the relevant offences. Make sure you understand what activity falls within each before selecting.

Your SAR must clearly describe the suspected criminal or terrorist property, including:

• What the property is that you suspect to be criminal. This may be funds intended to be used for a purchase, or the subject of a sale where you suspect the asset was originally acquired with criminal funds — be specific.
• Its estimated value
• Where it is located (this may still be within the asset if it has not yet been sold)

Step 7: Describe the Future Specified Activity

A DAML must relate to a specific activity that is yet to take place. The activity cannot be hypothetical. You should include all transactions or activities that are due to occur, for example:

• Facilitating a sale or let
• Receiving commission
• Forwarding payments

Remember: you are not asking for permission — you are asking for a defence. The NCA cannot assume, infer, or guess, so be specific about why you are suspicious and the offences for which you are seeking a defence.

Need more help? 

Click here to download our SAR Pre-Submission Checklist to make sure you haven’t missed anything before submitting you submit.

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FAQs

Are SARs crime reports?

No. SARs do not replace police or other reporting routes.

Can documents be attached to SARs?

No. Attachments are not permitted. Relevant content from documents should instead be described or referenced within the body of the SAR.

Do I need to include everything I know?

No. Focus on information relevant to explaining the suspicion.

What is the difference between an Intelligence SAR and a DAML?

An Intelligence SAR reports a suspicion where there is no future acts to be conducted which would require a defence eg the transaction is complete or no longer proceeding. A DAML is required where you need a defence before carrying out a transaction or activity that might otherwise constitute a money laundering offence.

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