Crying wolf: an examination of the UK's suspicious activity report regime

Research output: Contribution to journalArticlepeer-review


The Suspicious Activity Report (SAR) has been argued to be the bedrock of money laundering reporting in the UK.1 According to the National Crime Agency2 (NCA), an SAR is a piece of information alerting law enforcement agencies (such as the police) that certain client/customer activity is in some way suspicious and might indicate money laundering or terrorist financing. Persons in the regulated sector (such as banks) are required under Pt 7 of the Proceeds of Crime Act 2002 (POCA) to submit an SAR in respect of information that comes to them in the course of their business if they know, or suspect, or have reasonable grounds for knowing or suspecting, that a person is engaged in, or attempting, money laundering or terrorist financing. An SAR must be submitted as soon as is practicable.3 What looks like a simple decision is a complicated venture, which is traditionally performed by state institutions such as prosecutors and courts. In terms of the fight against money laundering, the judgment about whether a transaction is suspicious or not has been transferred to financial institutions.4 In other words, financial institutions (i.e. banks) are required by law to have the ability to identify any transaction of a customer that is from a legal or illicit source.5
Original languageEnglish
Pages (from-to)107-115
Number of pages9
JournalThe Company Lawyer
Issue number4
Publication statusPublished - 1 Apr 2019
Externally publishedYes


Dive into the research topics of 'Crying wolf: an examination of the UK's suspicious activity report regime'. Together they form a unique fingerprint.

Cite this