The Importance Of Good Quality SARs

Suspicious Activity Reports (SARs) – sometimes known as Suspicious Transaction Reports (STRs) – form a vital link between the police and key professions, from financial institutions and solicitors to accountants and estate agents. Last year saw over 3.5 million SARs submitted in the US, almost 1 million in the UK, and many millions more across the globe.

Given this volume, we can see why it is crucial that SARs are informative, succinct, and of high quality; verbosity, inaccuracy, or sloppiness will neuter their effect and potentially obfuscate important information that may otherwise have exposed criminal activity.

What Is A SAR?

A SAR is exactly what it says it is – a report outlining potential suspicious activity. They furnish law enforcement with important intelligence and information from organizations that they may not otherwise have been aware of. SARs can be used to report all manner of potential criminal activity and economic crimes.

In most jurisdictions, it is a requirement for employees of firms in the regulated sector to submit a SAR if they come across information that leads them to believe that money laundering or terrorist financing is taking place. For example, in the UK, individuals are required under Part 7 of the Proceeds of Crime Act 2002 (POCA) and the Terrorism Act 2000 to:

submit a SAR in respect of information that comes to them in the course of their business if they know, or suspect or have reasonable grounds for knowing or suspecting, that a person is engaged in, or attempting, money laundering or terrorist financing.[1]

In most jurisdictions, SARs are received, analyzed, and disseminated by a financial intelligence unit (FIU). The FIU in the UK is the National Crime Agency (NCA); in the US, it is the United States Department of the Treasury Financial Crimes Enforcement Network (FinCEN); and in Singapore, it is the Suspicious Transaction Reporting Office (STRO). It is a requirement for all members of the EU to have a designated FIU under EU regulations to comply with international standards.

Why Are SARs Important?

SARs provide a link between firms and law enforcement. This enables law enforcement to obtain information to which they wouldn’t formerly have been privy, which is instrumental in tracking down murder suspects, locating drug dealers or sex offenders, identifying victims of trafficking, or tracing those involved in distributing illicit material.  

Secondly, some SARs provide law enforcement with an immediate opportunity to locate and arrest criminals. At the same time, other SARs help highlight potential criminal activity that needs to be investigated or intelligence that is useful for future investigations. This leads nicely to the third point: SARs provide law enforcement with information relating to new or emerging types of organized crime or changes in criminals’ methods. This helps enable earlier detection and prevention, as well as giving the police the opportunity to issue alerts warning businesses of potential threats.

Finally, as the NCA states:

SARs can also help establish a geographical picture or pattern of the vulnerability of a particular sector or product and can be used in the analysis of suspicious activity before and after a specific event, such as a terrorist incident.[2]

Submitting Good Quality SARs

It is key that when SARs are submitted that they are of high quality. Good quality SARs make it easier for FIUs to analyze and disseminate; they also affect the ability to prioritize and process the reports, as well as have an impact on the applicable agency’s decision or ability to investigate. If they are poor, it can lead to unnecessary delays. SARs should include as much detail as possible so that the FIU obtains a clear picture of your concerns. The details you provide should enable the FIU to establish the following:

  • who is doing what
  • who they are/were doing it with
  • when they are/were doing it
  • why they are/were doing it
  • where they did it, and
  • how they are doing it.

The NCA has published guidance[3] on submitting better quality SARs, which includes requirements for the basic structure of SARs, what information to include, and what to leave out.

Example Case Studies

SARs have assisted law enforcement in capturing criminals involved in all kinds of illicit activity, from drug dealing to human trafficking to loan sharking. Below are a couple of examples of the success of providing good quality SARs can bring.

Example one

A multi-agency money laundering/marijuana trafficking investigation was initiated following the filing of a SAR by a bank in Tennessee. The SAR disclosed that an individual was depositing large amounts of U.S. currency into three bank accounts. The deposits ranged from $5,000 to $25,000, with the majority of the deposits consisting of one hundred dollar bills. Approximately $1.2 million was deposited into these accounts during a one-year period. Thus far, seven defendants have been indicted on multiple counts of money laundering and marijuana trafficking.[4]

Example two

A bank filed a SAR on an elected official from a suburban locality who structured transactions totaling hundreds of thousands of dollars. The SAR triggered an investigation that confirmed the structuring and identified evidence that the elected official committed perjury while filing a bankruptcy petition. Additional SARs filed on the defendant detail structuring at the bank as well as at a money services business.

Even though the defendant claimed he was bankrupt, in an 18-month period he made over 1,000 deposits at several different bank locations into his accounts totaling more than $500,000. His defense attorney stated that his business dealings took place throughout a large area, making cash transactions at different locations a necessity and not a means of attempting to avoid reporting requirements.[5]

To learn more about suspicious activity reporting, why not consider enrolling in the ICA’s short course ‘Managing SARs Investigations – Best Practice Guide.’

Written by Jon Prentice

This article was first published by the International Compliance Association (ICA), the leading professional body for the global regulatory and financial crime compliance community. For more information on the benefits of becoming an ICA member, including access to the ICA’s complete content library of articles, videos, podcasts, blogs, and e-books, visit: Become an ICA Member – Application Form (


[1] National Crime Agency, ‘Suspicious Activity Reports’

[2] National Crime Agency, ‘Suspicious Activity Reports’

[3] National Crime Agency, Guidance on submitting better quality Suspicious Activity Report (SARs)

[4] Financial Crime Enforcement Network, ‘SAR Filing Results in Arrests on Drug Trafficking and Money Laundering’

[5] Financial Crime Enforcement Network, ‘Suspicious Activity Report Leads to the Investigation and Conviction of Elected Official’

Lavanya Rathnam

Lavanya Rathnam is an experienced technology, finance, and compliance writer. She combines her keen understanding of regulatory frameworks and industry best practices with exemplary writing skills to communicate complex concepts of Governance, Risk, and Compliance (GRC) in clear and accessible language. Lavanya specializes in creating informative and engaging content that educates and empowers readers to make informed decisions. She also works with different companies in the Web 3.0, blockchain, fintech, and EV industries to assess their products’ compliance with evolving regulations and standards.

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