How and When to File a Suspicious Activity Report (SAR) – A Practical Guide for TCSPs

If you’re a Trust or Company Service Provider (TCSP) in the UK, knowing how and when to file a Suspicious Activity Report (SAR) is vital to staying compliant and protecting your business. In this guide, we’ll walk you through the key steps in spotting suspicious activity, when a SAR is necessary, and how to submit one properly – with practical tips along the way.

What Is a Suspicious Activity Report (SAR)?

A SAR is a disclosure made to the UK’s National Crime Agency (NCA) when you suspect that a person or company is involved in money laundering or dealing with criminal property. Under the Proceeds of Crime Act 2002 (POCA) and Money Laundering Regulations 2017, it is a legal obligation for regulated businesses like TCSPs to file a SAR when suspicion arises.

What Counts as Criminal Property?

Criminal property is any money or asset gained through criminal conduct. This includes:

Fraud and scam payments
Proceeds of tax evasion or bribery
Unauthorised trading or hidden ownership

Why Filing SARs Matters

Filing a SAR shows that your business is aware of suspicious behaviour and is taking appropriate steps to prevent financial crime. It’s not just about ticking a box – it’s about actively safeguarding your business and protecting your clients.

💡 Flex Tip: HMRC looks favourably on proactive SAR submissions. Logging and documenting SARs properly is a key part of passing an AML audit.

When Should TCSPs File a SAR?

You should file a SAR as soon as you have reasonable suspicion. You don’t need hard proof – suspicion alone is enough.

Here are common triggers:

🔍 Identity Fraud or False Documentation

Fake or altered ID documents
Someone using another person’s identity
Disappearing after being asked for proof

🏢 Suspicious Company Structures

One person sets up many companies with no clear business model
Apparent ‘fronts’ where PSCs don’t understand the business
Reluctance to provide CDD or explain control

📰 Adverse Media or Criminal History

Directors linked to scams or fraud in the news
Previous convictions for money laundering
Legal action against the business or individuals

🚫 High-Risk Business Types or Jurisdictions

Import/export, art dealers, crypto services
Links to high-risk countries (e.g. Myanmar, Iran)
Vague business activities or overly broad service descriptions

💰 Unusual Payments or Banking Behaviour

Third-party payments from unrelated accounts
Large cash sums or round-number deposits
Personal accounts being used for business income

🧾 Attempts to Circumvent KYC

Avoiding ID checks
Cancelling when challenged
Mismatched documents or suspicious changes

🔒 Sanctions Exposure

Match found on the UK Sanctions List
Links to restricted countries or blacklisted firms

💡 Flex Tip: Use the OFSI Consolidated List for all sanctions checks. Always screen UBOs and PSCs.

Filing a SAR: Step-by-Step

Visit the SAR Online Portal (National Crime Agency)
Provide:
- Subject’s details (name, role, company)
- Description of suspicious activity
- Nature of criminal property
- Source and flow of funds
Stick to facts – explain the rationale behind your suspicion without guessing
Attach any relevant documentation (ID, communications, invoices)
Log the SAR in your secure SAR register (not your client file!)

💡 Flex Tip: We have a ready-to-use SAR log template available – just ask!

🛡What Happens After You File?

Once submitted, the NCA may:

Contact you for more information
Issue a DAML (Defence Against Money Laundering) if needed
Request a transaction delay

If you don’t hear back, that’s normal. You must never inform the client about the SAR – this could be considered “tipping off”, a criminal offence.

Final Checklist Before Submitting a SAR

Do I have reasonable suspicion?
Have I documented my rationale?
Have I consulted my MLRO (if required)?
Have I stored everything securely?

Need Help with SARs or AML Compliance?

At Flex AML, we support TCSPs with:

SAR log templates
AML policies tailored to your business
Practical training and audit preparation

📅 Book your free 30-minute consultation at flex-aml.com – let’s take the stress out of AML.