Overview
Money laundering poses a significant threat to the UK’s financial system, enabling organised crime groups to conceal illicit funds and sustain their criminal activities. The National Crime Agency (NCA) leads the UK’s efforts to combat this threat through its UK Financial Intelligence Unit (UKFIU), which is responsible for processing Suspicious Activity Reports (SARs). These reports are essential tools that notify law enforcement of potential money laundering, terrorist financing, or other serious criminal offences.
According to the NCA SARs Annual Report 2024, 872,048 SARs were received in 2024 alone, providing vital intelligence to support investigations and enforcement.
The Threat from Money Laundering
Although there are no precise figures, the NCA estimates that money laundering impacting the UK likely runs into the hundreds of billions of pounds annually.
High-end money laundering, typically involving large sums channelled through financial and professional services, is particularly damaging, as it erodes trust in the UK’s global financial reputation. Criminal actors aim to exploit vulnerabilities such as cash-intensive businesses, UK corporate structures, and emerging technologies.
A notable case from February 2024 saw two individuals sentenced for laundering over £12 million in criminal proceeds using cash couriers and cryptocurrency platforms, demonstrating the sophistication of modern laundering methods.
What Qualifies as Suspicious Activity
A SAR is a piece of information which alerts law enforcement that certain client/customer activity is in some way suspicious and might indicate money laundering or terrorist financing. The SARs Reporter Booklet published in March 2025 highlights how critical SARs can be to law enforcement agencies.
It is important to remember that there is no universal definition of what constitutes suspicious activity. An action may be suspicious in one context but appear ordinary in another. Generally, a transaction or behaviour may be deemed suspicious if it is inconsistent with what is expected for that client or entity, based on their known profile or historical activity.
SARs are confidential and shared solely between the UKFIU and the reporting entity.
When to Submit a Suspicious Activity Report
As soon as you ‘know’ or ‘suspect’ that a person is engaged in money laundering or dealing in criminal property, you must submit a SAR.
A suggested internal process for identifying suspicious activity includes:
- Initiate an Internal Review after notifying the Compliance Officer or Nominated Officer
- Isolate the Risk (this could include temporarily freezing accounts or transactions)
- Document Findings
- Responsible person determines whether a SAR needs to be submitted
- Record Evidence
- Refine processes and procedures and train staff to address identified vulnerabilities
How to submit Suspicious Activity to the NCA
The NCA provides a free, secure and 24/7 SAR Portal for submitting reports, accessible via the NCA website. Firms must register for the portal, ensuring only authorised personnel, such as nominated officers, submit SARs.
To file a SAR, firms must complete a structured form including:
- The subject’s identity and relevant details
- Description of suspicious activity
- Justification for suspicion
Since the launch of the SAR Portal and reporter re-registration process, Banking and Financial Services continue to represent the largest proportion of SAR reporters, representing a total of 78.55% of total SARs submitted via the SAR Portal in 2024.
Consequences of Failing to Report
Failure to submit a SAR when required constitutes a criminal offence under the Proceeds of Crime Act 2002 (POCA) and the Terrorism Act 2000, exposing individuals and firms to serious legal and reputational risk. Individuals or firms that knowingly or negligently handle criminal property without reporting suspicion may face prosecution, with penalties including up to 7 years’ imprisonment, fines, or both.
In February and March 2024, the NCA’s efforts led to 438 arrests and £13.9 million in asset seizures, underscoring the consequences for criminals and complicit parties.
Submitting a SAR protects firms from liability, enhances compliance with FCA regulations, and contributes to national security. Firms must train staff to recognise and report suspicious activity promptly to avoid these severe consequences.
How Complyport Can Help
We specialise in empowering firms to navigate the complexities of their AML obligations and SAR requirements under the Proceeds of Crime Act 2002 and FCA regulations. Our tailored services help firms mitigate the risks of money laundering, ensure compliance, and protect against severe penalties.
We offer bespoke solutions including:
- AML Healthchecks;
- HMRC Supervision – Registration and Compliance Support;
- AML Policies, Procedures and Controls;
- Financial Crime Assurance Review;
- Financial Crime Business Wide Risk Assessment (BWRA) Support;
- FCA Annual Financial Crime Reporting (Rep-Crim);
- KYC/CDD/EDD Outsourcing;
- AML Training for staff (online or face to face);
- Financial Crime Annual Retainer.
Book a meeting with one of our Subject Matter Experts to ensure you remain compliant and well-positioned in the evolving UK regulatory landscape.
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