Reporting suspicious activity

A person who has knowledge or suspicion of money laundering or terrorist financing must report their concerns to their Money Laundering Reporting Officer (MLRO). It is a criminal offence if they fail to do so.

Knowledge or suspicion of money laundering or terrorist financing must be reported to the Money Laundering Reporting Officer (MLRO). The MRLO has a duty to consider all such reports.

If the MLRO also suspects money laundering or terrorist financing then they must make an onward disclosure (otherwise known as a suspicious activity report) to the National Crime Agency.

Please see the sector guidance for more information on suspicious activity reporting and your obligations.

New supplemental CIMA guidance on SARs.

UK Guidance on court orders

Tipping Off

The dilemma between providing professional clearance information and safeguarding against tipping-off can be a difficult one to navigate. The CIMA Professional Standards Department has enhanced its guidance in this area and also signposts to other guidance and further reading.

UK SAR Codes

For members in the UK, the National Crime Agency (NCA) has published Guidance on Submitting Better Quality Suspicious Activity Reports (SARs)

When submitting a SAR all data fields, SAR glossary code and reason for suspicion must be included within the SAR.

Further guidance on SAR glossary codes can be found using the link below:

SAR glossary codes

Ireland - Suspicious Transaction Reports

The Financial Intelligence Unit Ireland goAML system allows reporting entities to submit STRs electronically to the FIU.

This will be through the FIU-Ireland website which features the goAML online system.

Prior to being able to submit an STR online, the Money Laundering Reporting Officer (MLRO) must register their entity on the FIU Ireland website. Please see the below guidance from the Department of Justice and Equality:

Reporting Entity Registration Guide

Reporting Entity Go Live Pack

goAML FAQs

Please see the following guidance which gives step by step instructions on how to submit an STR:

goAML quick reference guide

Please see the following guidance on how to find and amend a rejected STR:

How to amend rejected STRs

goAML will provide a number of benefits, including secure submission of STRs, electronic receipts for submitted STRs, and a message board that will allow a reporting entity to communicate directly and securely with the FIU (including for the FIU to contact the reporting entity on trends and typologies from the analysis of STRs).

Please note that while a reporting entity will receive an automatic acknowledgement when an STR is accepted by the FIU, periodic feedback as to the status of each STR will cease. If the FIU needs to communicate with the MLRO on individual STRs, this will be done via the secure message board.

Financial Sanctions

Who is subject to financial sanctions in the UK?

A guide to the current consolidated list of asset freeze targets, and a list of persons subject to restrictive measures in view of Russia's actions destabilising the situation in the Ukraine.

Please see the financial sanctions consolidated list for more information.

Defence against anti-money laundering (DAML)

This guidance note is produced in line with the National Crime Agency (NCA) commitment to share perspectives on the Suspicious Activity Reports (SARs) regime. It provides good practice provided by experienced Money Laundering Reporting Officers (MLROs) from across the UK Suspicious Activity Reports (SARs) regime.

It is intended to help SAR reporters provide good quality Defence Against Money Laundering (DAML) SARs.

For more guidance on defence against Anti-Money Laundering please see here (PDF 238KB)

UKFIU SAR Guidance

The UKFIU has provided a useful guidance on how to submit a SAR

UKFIU SARs Guidance

UKFIU Online Quick Start Guide

Further Information

Reporting suspicions within the UK - National Crime Agency (NCA)