Home Office strikes blow against defensive SARs

Guidance from the Crown Prosecution Service and the Home Office ups the ante on relevant officers to submit Suspicious Activity Reports where appropriate, but not to succumb to over-filing. The emphasis is on firms suitably managing their risks and not using an easy escape route, comment Maria Evstropova and Julius Kania.

Maria Evstropova(www.kroll.com/en/our-team/maria-evstropova)is director, Financial Services Compliance and Regulation, whileJuliusKaniais vice president, Financial Services Compliance and Regulation, atKroll.

In June 2019, the Law Commission for England and Wales published its long-anticipated report on the United Kingdom SARs (Suspicious Activity Reports) regime, setting out several recommendations for improvement. [1] These recommendations resulted in the Government initiating a SARs Reform, a multi-year programme supporting the delivery of the UK’s Economic Crime Plan by ensuring that the SARs regime: protects the integrity of the regulated sector, supports the disruption of money laundering, terrorist financing and predicate offences, as well as operates effectively and efficiently across the public and private sectors. [2]