Yesterday, 24 January 2023, the National Crime Agency (NCA) published the 2022 Suspicious Activity Report (SARs) Annual Report.

SARs are submitted to the NCA by individuals working in regulated sectors such as banking, legal and financial services, where they suspect that transactions are being used to launder money or conceal criminal activity. The Annual Report covers 20/21 and 21/22.

Key points are:

  • 901,255 SARs were received and processed - a 21% increase on the previous year;
  • £305.7M denied to suspected criminals as a result of Defence Against Money Laundering (DAML) requests – a 120.6% increase on the £138.6M denied in 2020-21.

In 2022, the NCA set up the new Combatting Kleptocracy Cell (CKC), with a remit that includes the investigation of criminal sanctions evasion and high-end money laundering. As a result of Russia's conflict with Ukraine, SARs have provided increasingly important information on money laundering linked to sanctioned individuals and their associated entities.

SARs are an important component of the information coming into the Cell, and the UK Financial Intelligence Unit (UKFIU), which receives, processes and assesses SARs on behalf of the NCA, now has a dedicated team to work as part of the CKC.

Under the SARs Reform Project, the UKFIU has undertaken a significant transformation since the last report, with new methods of working and new teams. This has included an uplift in staff to over 150 and measures are in place to reach the target of 201 by the end of the next financial year, driving increased analysis and engagement within the SARs regime.

March 2022 saw the Economic Crime (Transparency and Enforcement Act) 2022 enacted. I wrote about this at the time. The Economic Crime and Corporate Transparency Bill is at the reading stage in the House of Commons. The Bill includes provisions to strengthen anti-money laundering powers, enabling better information sharing on suspected money laundering, fraud and other economic crimes. 

Should you require assistance or advice on SARs or any financial crime query, please do not hesitate to contact our Regulatory Solutions team.