Reporting suspicions of money laundering

The following Risk & Compliance practice note provides comprehensive and up to date legal information covering:

  • Reporting suspicions of money laundering
  • What is a suspicious activity report?
  • Principal money laundering offences
  • Failure to disclose offences
  • Failure to disclose—regulated sector
  • Failure to disclose—nominated officers in the regulated sector
  • Failure to disclose—other nominated officers
  • Disclosure under the Terrorism Act 2000
  • Penalties
  • Suspicious activity reporting system
  • More...

Reporting suspicions of money laundering

This document reflects draft Legal Sector Affinity Group (LSAG) AML guidance, published on 20 January 2021. It awaits HM Treasury approval. Note that any content may be amended before the final version is published with the Treasury's approval. 

You may have a regulatory or professional duty to keep the affairs of your customers confidential and the circumstances in which you can disclose information about your customer may be very limited.

The Proceeds of Crime Act 2002 (POCA 2002) imposes an obligation to report knowledge or suspicions of money laundering by way of a suspicious activity report (SAR). There are heavy criminal sanctions for failing to do so.

This Practice Note sets out your reporting obligations under the POCA 2002 and gives practical guidance on how to comply. It provides guidance which is of general application. You should check whether the law or your regulatory body has any additional, sector specific requirements in relation to reporting suspicions of money laundering.

What is a suspicious activity report?

A SAR is a report made under POCA 2002. It can be:

  1. an internal SAR to your nominated officer, or

  2. an external SAR to the National Crime Agency (NCA)

Principal money laundering offences

You will have a defence to a principal money laundering offence if you make a SAR to the NCA and you receive appropriate consent (or a defence, in the NCA’s

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