Anti-Money Laundering Compliance and the Legal Profession

6 The suspicious activity reporting (SARs) regime

DOI: 10.4324/9780429019906-6

The previous chapter focused on some of the mechanical aspects of the UK AML regime surrounding CDD, AML training and the client account. The focus in this chapter is on one of the ‘central’ weapons in the UK’s AML armoury, that of the SARs regime, which is a key aspect of the prevention pillar upon which the UK’s AML framework rests.¹ Under this regime, legal professionals report their knowledge or suspicions of money laundering, on the basis that such SARs have ‘the potential to be a critical intelligence resource’, used both to disrupt laundering and contribute to investigations.² Thereafter, with an exploration of the compliance issues relating to the mechanical ...