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Anti-Money Laundering & Financial Crime Prevention
Lesson 5: Reporting & Escalation
SARs, the NCA, internal reporting, and tipping off obligations
Overview
Suspicious Activity Reports
  • Hundreds of thousands of SARs filed with the NCA every year
  • Each one begins with a single person noticing something
Scenario
Spotting the Unusual
  • Multiple payments from unrelated individuals
  • Amounts just below £10,000 each
  • No obvious business reason
Step 1
Document Everything
  • The dates, the amounts, the senders
  • And why it concerns you
  • “It seemed odd” is not enough
  • The NCA needs clear, detailed intelligence
Step 2
Report to the MLRO
  • The Money Laundering Reporting Officer
  • Every regulated firm must appoint one
  • Your single point of contact for suspicious activity
Step 3
The MLRO's Decision
  • Reviews your report and assesses whether suspicion is well-founded
  • Decides: file a SAR with the NCA, or record the rationale for not doing so
The SAR Process
Filing with the NCA
  • Submitted through the NCA's secure portal — 24/7
  • Full details, clear reasoning, no jargon
  • May be read by non-specialists in law enforcement
Consent Regime
Defence Against Money Laundering
7 days
NCA response window (working days)
  • Silence means deemed consent
Consent Regime
If the NCA Refuses Consent
  • A moratorium applies — transaction cannot proceed
217 days
maximum total moratorium
Critical Rule
Never Tip Off the Customer
  • Never tell the customer a report has been filed
  • Not directly, not indirectly, not even a hint
  • This is the offence of tipping off under POCA
Penalties
Tipping Off: The Penalty
2 yrs
maximum for tipping off
  • Even a well-intentioned warning is a criminal offence
Protection
Safe Harbour for Honest Reporters
  • You cannot be sued for breach of confidentiality
  • Cannot be disciplined by your employer
  • The system rewards those who speak up
Penalties
The Cost of Silence
5 yrs
maximum for failure to report
  • Your silence is not neutral — it is a choice with consequences
Your Duty
You Do Not Need to Be Certain
  • You do not need to investigate
  • You do not need to build a case
  • Just report your concern and let the professionals handle it
Your Obligation
Suspect It? Report It.
  • Suspect it? Report it.
  • Document it. Let the MLRO and NCA do the rest.
  • That is your legal obligation — and your protection
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