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.
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 new SAR reporting Glossary codes which are effective from 1 September 2016. Numerous changes have been made to assist the NCA in quicker identification of SARs which require fast-tracking and prioritization.
UKFIU Communication Change to Glossary codes and clarification of reporting routes.pdf (PDF 85KB)
Click here for the new list of UK SAR Glossary Codes October 2016.pdf (PDF 240KB)
Ireland - Suspicious Transaction Reports
The Financial Intelligence Unit Ireland will be acquiring a new IT software solution, called goAML. The goAML system will allow reporting entities to submit STRs electronically to the FIU. This will be through the FIU-Ireland website (which will feature the goAML system) once it goes live.
Prior to being able to submit an STR online, the Money Laundering Reporting Officer (MLRO) must register his/her entity on the FIU Ireland website. Please see the below guides from the Department of Justice and Equality:
Reporting Entity Registration Guide
Reporting Entity Go Live Pack
Once an STR has been accepted by the FIU, this exact STR can be printed and forwarded to the Office of the Revenue Commissioners (RC) as is currently the procedure. The FIU is currently engaging with the RC with regard to goAML – while the RC is not, at this juncture, planning to acquire goAML, they are exploring available options which would allow for them also to receive STRs electronically. The RC have stated that they are willing to receive STRs in this goAML format as opposed to being handwritten/typed on the traditional STR form (Form ML1). Please see the following guide which gives step by step instructions on how to submit an STR:
goAML quick reference guide
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.
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 (PDF 22KB)
Accountancy Sector SAR Template
A useful SAR Template provided by the Accountancy sector to help guide you through the SAR process Accountancy Sector SAR template (PDF 44KB)