Webinar Wrap-Up: Filing a SAR – A Practical Guide from the NCA

Art Market Participants (AMPs) operate in a highly regulated space, and meeting Anti-Money Laundering (AML) obligations is not just about good practice – it’s a legal requirement. One of the most critical responsibilities is the submission of Suspicious Activity Reports (SARs) to the National Crime Agency (NCA).

To help AMPs navigate this complex area with confidence, FCS Compliance recently hosted a dedicated webinar in partnership with the NCA. Held on Monday 7 April, the session featured expert guidance from Beth Dale, Senior Officer at the NCA, who explored the obligations and practicalities around SARs – particularly the Defence Against Money Laundering (DAML) SAR.

What Was Covered

The session offered an invaluable deep dive into the legal and procedural aspects of SARs – when you must submit one, how to assess suspicion, and what happens after a report is filed. AMPs gained a clearer understanding of:

• The different types of SARs and when they apply
  
  
• What constitutes “suspicion” in the eyes of the regulator
  
  
• How to handle red flags that arise, even if a transaction is ultimately not completed
  
  
• Why timely and well-constructed SARs help mitigate criminal exposure
  
  

Beth Dale also clarified that a DAML SAR can only be filed in relation to activity that has not yet taken place – a crucial detail for any AMP unsure about the process.

An Eye on the Bigger Picture

The discussion also touched on broader reporting trends. While the 2024 SARs Annual Report shows that AMPs and High Value Dealers (HVDs) are still under-reporting overall, there has been a slight increase in DAML SAR submissions – a sign that awareness is growing. The NCA continues to encourage the sector to be proactive and precise in identifying and reporting suspicious activity.

A Resource to Support You

Attendees received a helpful handout from the NCA to support ongoing learning and compliance – a valuable tool to reference when making reporting decisions.

At FCS Compliance, we understand that AML obligations can feel complex and high-stakes – especially when the commercial pressures of art fairs and private sales are at play. Our goal is to ensure you feel equipped, not overwhelmed.

If you missed the session or have further questions about SARs or any aspect of your AML programme, our team is here to help. Contact us here.