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May 2020: NCA guidance on making better SARs

There’s much more in this document, but I thought I’d highlight Section 6 (“good practice tips):

Always
 identify as clearly as possible the suspected benefit from criminal conduct (the ‘criminal property’) including, where possible, the amount of benefit
 identify the reason(s) for suspecting that property is criminal property
 identify the proposed prohibited act/s you seek to undertake involving the
criminal property
 identify the other party/parties involved in dealing with the criminal property, including their dates of birth and addresses where appropriate (such information should be held routinely by reporters in the regulated sector to comply with the requirements of the Money Laundering Regulations)
 describe fully the reasons for suspicion in relation to money laundering. As a basic guide, wherever you can, try to answer the following six basic questions to make the SAR as useful as possible: Who? What? Where? When? Why? How?
If your SAR relates to the purchase/sale of a property include:
 the full address of the property and postcode
 the value of the property
 the date of activity
 how the activity will take place or has taken place
 the full identity, where known, of the other party/parties involved in dealing with the property, including, in particular, if they are providing professional services e.g. solicitor, estate agent, accountant or company formation agent etc.
If your SAR relates to a vulnerable person:
 describe fully the vulnerabilities that you believe suggest the person cannot protect him/herself against exploitation e.g. do your concerns relate to what appears to be mental, physical or learning disability, or an illness related condition?
 describe if law enforcement or other agencies are aware of the circumstances (if so, include that organisation’s reference numbers, details of the officer contacted etc.)
If your SAR relates to a professional enabler:
 describe the services being provided e.g. “the professional services being provided are…” (e.g. accountancy insolvency, audit, company formation, property conveyance, legal services etc.)
 include:
– the date of activity
– how the activity will take place or has taken place
– full identity, where known, of the other party/parties involved in, including in
particular, the type of professional services being provided e.g. solicitor, estate agent, accountant or company formation agent etc.
 describe if suspicion relating to the services being provided appear to be wittingly or unwittingly facilitating the money laundering described
 describe the indicators suggesting complicit criminal behavior or negligent behavior of the professional(s) involved.

Link:

NCA SARs guidance

Categories: Anti-Money Laundering Best Practices Guidance Suspicious Activity Reports UK Resources

eric9to5

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