When a SAR is submitted with missing or incomplete information, it affects
the NCA's ability to prioritise and process the report, and for the relevant
Law Enforcement Agency to make an educated decision on whether a defence can be
granted or whether the report needs to be investigated further.
Examples of significant omissions are:
- Identifying features – particularly subject name (first/middle/last) and
date of birth; also address, passport information, driving licence information, etc.
(Note: these details can be omitted if the business was aborted before the commencement of the KYC process)
- Detailed reason/s for suspicion – outline what has brought about your suspicion,
in line with what you know about the client’s business and typical behaviour.
What is usual and what has changed? Note that it is not sufficient or appropriate to
state words to the effect of ‘I am not suspicious of this client but am making this report anyway.’
- Details of secondary individuals associated with the transaction
- Consent box not ticked when a defence against money laundering or terrorist financing is being sought
- Information as to why a defence is required – e.g. entering into an arrangement, facilitating, concealing, etc.
For further guidance on submitting a good-quality SAR, please vist the NCA website -