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You have a reportable suspicion if you think there’s a possibility, which is more than fanciful, that the relevant facts exist. The leading test comes from R v Da Silva EWCA Crim 1654. You’ll need to decide whether you’ve formed a suspicion before you’re obliged to make a SAR. If you're an MLRO working in the non-regulated sector, you must make a SAR if you know or suspect that money laundering is taking place. If you’re an MLRO working in the regulated sector, you must make a SAR if you know or suspect, or have reasonable grounds for knowing or suspecting, that a person is engaged in money laundering. Read our guidance on identifying money laundering When to make a SAR Regulated sector whether the client is a suspect or a victim.Identifying money launderingīefore making a SAR, you need to be clear about who you’re reporting and why. If you’re a solicitor or member of staff working in a law firm or legal practice, read our guidance on reporting money laundering. It assumes that the person making the SAR is a money laundering reporting officer (MLRO) or their deputy. This guide explains how to report suspicious activity to the NCA. terrorist financing – under part 3 of the Terrorism Act 2000 (TACT).money laundering – under part 7 of the Proceeds of Crime Act 2002 (POCA).A suspicious activity report (SAR) is a disclosure made to the National Crime Agency (NCA) about known or suspected:
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