Video: How to submit better quality Suspicious Activity Reports
Claire Wilson (CW): Thank you for joining us, I’m Claire Wilson. I lead on the anti-money laundering and counter terrorism financing strategy for the Gambling Commission. I worked for the Commission for 11 years and prior to that I worked in the gambling industry for 15 years.
This video is being jointly made with our partners at the National Crime Agency. Our hope is to make available to you, a collection of videos that signposts of good anti-money laundering guidance and share with you some practical tips to help you with your SAR reporting and AML training.
The Commission recognises that operators submit good quality SARs and we want to maintain that quality and improve where we can.
The video box set will be released throughout September 2018 and each video will have a specific theme.
In each video we will share with your responses to questions raised at the Gambling Commission anti-money laundering forums and recent survey has been introduced on the Gambling Commission website.
The main focus of this video is to talk through how to construct a good quality SAR and why getting that quality right is so important.
I am pleased to introduce Tony Fitzpatrick from the National Crime Agency who has worked for the United Kingdom Financial Intelligence Unit known as the UK FIU for five year. Tony has first-hand experience dealing with a variety of SARs.
Tony Fitzpatrick (TF): Thank you Claire. Just one caveat I’d like to make viewers aware of, anything said in this video is meant to be helpful and it’s based on sharing experiences of what is seen in the SARs and also described by some experienced Money Laundering Reporting Officers or in some cases Anti Money Laundering consultants.
Any comments made during this video should not be treated as legal advice. If in doubt, please go and seek independent legal advice and they’ll give you the best way forward.
CW: So, Tony, what guidance for reporters to regard when making a SAR?
TF: There’s a very good document called “Guidance on submitting better quality suspicious activity reports”. This document provides all reports as guidance on how to submit better quality SARs into the NCA.
It can be found on National Crime Agency website www.nationalcrimeagency.gov.uk or just google “NCA better quality SARs” and it will be found.
CW: So, before we go into how to construct a SAR, what is the best way to submit a SAR into the National Crime Agency Tony?
TF: Simply put, it’s SAR Online. SAR Online is designed to allow SARs to be constructed and submitted in a secure manner. SAR Online available via a link in the top right-hand corner of the National Crime Agency website.
To register new users require an active email account which becomes the user’s SAR Online user identification. No two users can use the same email address.
It’s recommended that all registered users be an official responsible for either Anti Money Laundering compliance within the organisation or it could in fact be a Money Laundering Reporting Officer (MLRO).
Ensure that you register yourself correctly, that is make sure you are aligned to the correct sector and you’re aligned correctly to the right regulator or supervisor.
CW: So, Tony, what are the advantages of SAR Online?
TF: Well SAR Online, first of all it’s free and it’s a secure system. It negates the need for paper-based reporting. Once a report is submitted, an acknowledgement with a unique reference number is sent via email.
Reporters can make 24/7 reports, they can do it at any time, provided that the reporter has an email account and internet access.
There is helpful text and helplines available on every single page, there’s pop up tips also available on each page. SARs can be marked as private to an individual user. Shared viewing editing is available where appropriate.
A frequently asked question document is also available. A link providing background information on financial records available via the SAR Online homepage.
CW: Ok thanks Tony. So, if I’m constructing a SAR for the first time, what is the best basic structure of a SAR?
TF: Firstly, there are a number of fields to be complete. As much information as possible should be completed in the data fields. SARs should contain all available customer due diligence information.
Dates of birth are vital for identifying individuals correctly. In additional to the reasonable suspicion, you must fully populate all the other information fields.
Please use the word unknown to make it clear if you do not know the information. Please do not use an asterisk or a question mark. Please do not use a dot or leave blank, only use the word unknown.
Using other characters hinders the UKFIU and our colleagues in law enforcement, it hinders their analysis and also it distorts and makes it unclear why the reporter has put those symbols into the text. So only use the word unknown if you are not sure about particular information.
CW: Thanks Tony. So, I have filled out all of the fields required, what is your advice on wording the reason for suspicion?
TF: Well overall, I’d say be clear and be concise. The explicit rationale behind a reason for suspicion and the context of why the SAR has been submitted should be clearly communicated in simple straightforward English.
Structure your report in a logical format including all the relevant information. Briefly summarise your suspicion, provide a chronological sequence of events. Keep the content clear, concise, and simple. Please avoid using acronyms and jargon, they may not be understood by the recipient and might be open to misinterpretation.
If providing a service provided or a technical aspect of work, please provide a brief synopsis in your SAR to aid the reader.
Do not write the SAR in capital letters, this makes it very, very difficult to read.
If including a large amount of information or text, please break it up into paragraphs, make it more easy to read and more manageable. Very long SAR which are text heavy are very difficult to digest and understand. Use punctuation.
Separate bank account or transaction information into their usual standard sort code definitions.
CW: Thanks Tony. So how much detail is required for reasonable suspicion?
TF: The reasonable suspicion element is the rationale behind why the SAR was submitted and therefore should be very explicit.
In the reason for suspicion field, which is limited to 8000 characters and approximately 1500 words, try to answer these simple questions:
- who is involved?
- how are they involved?
- what is the criminal or terrorist property?
- what is the value of the criminal or terrorist property? And if need be give an estimate if you don’t know exactly.
- where is the criminal or terrorist property? Example is it in a casino in London, a property in Hampshire, etc.
- when did the circumstances arise?
- when are the circumstances planned to happen?
- how did the circumstances arise?
- why are you suspicious or why do you have this knowledge?
Suspicion is a very important factor when seeking a request against money laundering offence. It is also important from an analytical point of view.
The bulk of analysis we do focuses upon the free text searching of keywords, whilst it is acknowledged that no fields are currently mandatory, all fields should be completed where possible providing.
While the UKFIU appreciates it’s more time consuming, it is important that details are completed within the appropriate SAR Online fields and not solely placed in the reasonable suspicion field.
This enables UK FIU and law enforcement to link the multiple SARs containing the same information, especially bank account details. This network analysis is the greatest benefit that SARs provide.
CW: So, Tony, how would you start your reason for suspicion because that can be difficult when you have a lot of complex data and information to consider?
TF: Yeah, I appreciate that it is quite tricky the key message for me is try to identify to the reader at an early stage what the SAR is about in the first few sentences, in the first paragraph. I would suggest you take the following steps:
First of all, step one: start with a SAR glossary code at the beginning of your text, this is a good indicator as to what the SAR is about. Guidance on SAR glossary codes are also found on the NCA website and will form part of another video.
The next step would be to provide a good brief summary to highlight the key elements of your suspicions. Consider if there are any other useful information that you could add.
In the reason for suspicion field, you should also conclude with the intended action that you intend to take, example are you intending to exit the relationship, are you going to monitor the customer, are you going to continue with the relationship?
So, to summarise, completing all the SARs information fields is very important. Alongside completing the reason for suspicion, you should complete as fully as possible all the information known from your due diligence.
The amount of information you have may depend on your relationship with the reported subject. As I mentioned previously, if you don’t know the information, please populate that field with word unknown.
When discussing any information provided regarding individuals, it’s really important that you provide the full names, you provide the date of birth, where you know it the nationality and also include the address, and in that address include the postcode and use the usual format you would do for a UK or international postcode.
If you have the financial information you should also put that into the context of you reason for suspicion field. If you’ve got any information about identification documents, such as a passport, a driving licence, or National Insurance number, please put that in the SAR.
If you’ve got any additional information about types of cars being used, the colour or registration numbers, please put that in the SAR. Similarly, telephone numbers are very important. Please put them in a SAR and if you know if it is a home number or a business number or a mobile, please state that also.
Full details of bank accounts or other financial details are really important. Use standard format including the sort code where appropriate. Most importantly, always put the occupation of the subject into the SAR.
Providing the detail on the main subject patient assists in a number of ways. It helps the reader make judgments about the origin of funds. It also helps determine whether subject is being used as a professional enabler. Are they using some professional knowledge to facilitate money laundering? It also helps engage with regulators and supervisors for that professional body.
It’s appreciated that you may not have all this detail concerning these types of descriptions. The amount of information that you have will depend on your relationship with your subject, but again if you don’t know these key parts of information, please use the word or phrase “unknown”.
Addresses are very important to UKFIU, because the UKFIU use the postcodes to allocate SARs to the appropriate law enforcement agencies. Such allocations offer opportunities to take swift action or in some cases build a good intelligence picture.
Postcodes and international addresses are crucial, and they often affect analysis when we are looking at trends and particular hotspots in the country or in the world.
The post code and full address of the main subject should always be included where known and use standard format. Clarify the status of the address, for example, is it a current address? Is it a previous address? Do you know if it is residential or business, or is it a trading address or registered office etc?
Where details of a victim are known, in particular a vulnerable person situation, it’s very important we get all the postcodes available so we can help save that victim, where possible. So, if you’ve got any additional addresses that might help in that situation, please include them.
In all international address cases, whether it be the suspect, or associate or a potential victim, put at least, if you don’t know the code, what country it relates to, so that we can follow that up accordingly.
A final tip for me is how you deal with a subject or a suspect for a previous SAR. If the reported subject, example a client or customer, is also suspected in another set of circumstances and you need to put another SAR in, it’s important that you put the correct SAR reference number in when you refer to that person.
Please only use the SAR reference number given to you by the UKFIU. Do not include any internal reference numbers because that makes the reading and connectivity very, very difficult to understand.
Claire, how would you conclude what we have discussed in this video so far?
CW: Thanks Tony, so to conclude this video I think you have provided some really practical and useful tips for reporters submitting general SARs.
Of course, what we’ve discussed today can be found within the NCA’s guidance documents, and in particular, the guidance on submitting better quality SARs document, which is available on the NCA website.
So, thank you all for joining us today, and look out for our third video about how to submit SARs for a defence against money laundering.