Important AML update: key SAR reporting insights and how to make effective SARs

12 February 2025

The latest Suspicious Activity Report (SAR) Reporter Booklet highlights how SARs play a vital role in tackling financial crime. As Insolvency Practitioners, your ability to identify and report suspicious activity is crucial in protecting the financial system. The case studies in the booklet demonstrate how SARs have led to law enforcement freezing and recovering criminal funds, uncovering fraud and disrupting organised crime.

Effective SAR reporting: providing the right information

To ensure SARs are as useful as possible, they must be clear, concise and detailed. The right information helps law enforcement understand the context, prioritise cases, and take action. A well-structured SAR should include:

• Subject type: clearly classify the subject as a suspect, victim or unknown, to provide context and avoid confusion.
• Accurate subject details: for individuals, include full name, date of birth, addresses and key identifiers (e.g. NI number, passport number). For entities, provide registration number, VAT number, incorporation country and contact details.
• Relevant financial transactions: specify details such as account numbers, transaction dates, amounts, payment method, and why they are suspicious.
• Services provided: outline the nature of your appointment or work being undertaken that meant the information came into your knowledge.
• Explanation of suspicion: keep it clear and concise, describing what you’ve seen, why it’s unusual, and what underlying criminal activity may be involved.

(SARSE – Subject, Accurate details, Relevant transactions, Services provided, Explanation of suspicion)

Key ‘red flags’ to look out for

The SAR Reporter Booklet highlights common warning signs, including:

• Unexplained large cash deposits or rapid fund movements
• Business activity that doesn’t align with declared income or operations
• Identity fraud – fake company registrations or misuse of personal details
• Money muling – individuals receiving and transferring funds with no clear source

It is crucial that Insolvency Practitioners have procedures that ensure that ‘red flags’ are picked up in each and every case and appropriately reported. Your reports directly contribute to identifying criminal networks and recovering illicit funds. We encourage you to review the full SAR Reporter Booklet for more guidance. 

Further recommended reading: Guidance for Anti-Money Laundering supervisors on submitting better quality Suspicious Activity Reports