Emma RadmoreNCA has published an update to its guidance on how to submit better quality SARs, and a set of FAQs to accompany it. The guidance stresses that a properly made SAR will give the enforcement agencies a quick picture of who is doing what, where, when, why and how and will enable them to prioritise attention to DAML SARs. Most of the guidance is not new, but the messages bear repeating.
The guidance reminds reporters that every reporter must submit a SAR as appropriate under POCA or TACT, setting out the reason for suspicion, a description of the relevant property and the prohibited act they wish to carry out (where this is the case), and that there are additional obligations under POCA on those in the regulated sector including providing the identity of the person concerned, the whereabouts of the property and any information they have that might help.
Key other pointers include:
- the need to provide as much information as possible, including all available CDD information;
- using the word UNKNOWN where necessary rather than leaving boxes blank or using other characters;
- the need to be clear and concise, not using acronyms and giving a brief description of any relevant aspect of the business of the reporter necessary to help understand the context of the SAR;
- trying to answer all the key questions in the “reason for suspicion” field within the permitted 8,000 characters;
- making sure to fill in the right information in the right fields, including the right glossary codes, otherwise all the FIU systems will not pick up the best information;
- not sending attachments with the SAR;
- making sure DAML requests are clearly marked and properly directed and request consent for a specified activity
