Suspicious Activity Reports
The SAR form should only be used to report suspicious activity. It should not be used to report a fraud or an attempted fraud. Please see What we do for information on how these matters should be reported.
Persons in the regulated sector are required under Part 3 of the Proceeds of Crime Act 2008 ("POCA") and the Anti-Terrorism and Crime Act 2003 ("ATCA") 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. A SAR must be submitted to the FIU as soon as practicable.
An online reporting system, Themis, is available to MLROs to submit SARs. In order to use this system an application form should be submitted by the business to register its MLRO and any DMLRO's it has. The form is available to download from this page. For registered users there is also a link to the logon page of Themis.
By submitting a SAR to the FIU you will be providing law enforcement agencies with valuable information of potential criminality whilst ensuring appropriate compliance with your legal obligations to report under POCA and ATCA.
Once you have submitted your SAR you should remember your obligations not to make any disclosures which might constitute an offence of tipping-off under section 145 of POCA, or section 27 of ATCA.
The FIU does not provide or approve standard wording for you to use in such circumstances. It is therefore recommended that you give careful consideration to how you will handle your relationship with the subject once you have submitted the SAR, particularly if the subject is a client or customer of your business. You may wish to discuss with your supervisor, professional body or seek legal advice if you are unsure.
The FIU produces an annual report which includes statistics on SAR information. Prior to the creation of the FIU these statistics were published in the Chief Constable's Annual Reports. Typologies and trends are fed back to the industry through Advisory Notices and presentations given by the FIU, as well as in joint presentations and seminars with the regulators.
|Disclosure forms (Word format)|
|Online Reporting MLRO registration form|
|Themis User Guide v3'|