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Suspicious Activity Reports – Thematic Review, guidance and information

Author: ICAEW Regulation

Published: 26 Oct 2020

About this SARs guidance

The source of this guidance on suspicious activity reporting procedures and staff training is taken from the Suspicious Activity Reports (SARs) thematic review we carried out earlier in 2020. It forms part of our work to ensure the firms we supervise for anti-money laundering have the ability, competence and resources to identify and report suspicious activity promptly.

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ICAEW firms are providing useful information to law enforcement. 3 out of 5 Suspicious Activity Reports (SARs) reported to the NCA are from ICAEW firms. 

However, 21% of the firms surveyed reported they had not submitted any SARs to the NCA in 2019. 

To understand how and when our firms report SARs we undertook a SARs thematic review. Our aim was to:

  • collect data and look for trends and correlations that allow a greater understanding of vulnerabilities and threats;
  • identify ways in which firms can train staff to better spot potentially suspicious activities;
  • identify best practice; and 
  • see how we can help firms improve the quality of the SARs they submit.

We asked the firms about their procedures for reporting suspicious activities, staff training and the number and nature of internal and external SARs made annually. 

The firms we selected to survey for this review were assessed as potentially being at a higher risk of facilitating money laundering. This assessment was based on factors such as the risk profile of the client base and services provided. These factors are linked to the National Risk Assessment, which define higher risk services and client typologies. 

This report sets outs some of the quantitative data and trends we observed from the responses to the questionnaires. We have included a commentary on the responses, as well as our observations on what our firms are doing well and what could be improved.

 The number of SARs made to the NCA by the firms surveyed is analysed below (by firm size).

Firm turnover Average SARs per firm in 2019 Percentage of firms with no SARs
2000m + 128 0%
100 to 1,999m 85 0% 
20 to 99.99m 16 0%
10 to 19.99m 10 7%
5 to 9m 7 31%
1 to 4.9m 3 25%
0 to .99m 1 83%