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SAR Quality issues
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| These issues are widespread across the reporting sector, and affect
NCA's ability to
prioritise and process the report and Law Enforcement's decision or ability to
investigate and/or grant consent. Ultimately it affects the reporting sector,
because consent can be delayed causing face to face problems with your
customer/client, and generic case study feedback is not possible.
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| Significant omissions might include:
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No identifying features i.e. no dates of birth, no first/middle names, no
passport or driving licence information. (NB: this is not a problem if business
aborted because
KYC commenced).
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No occupation / employer.
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No reasons for suspicion i.e. 'I am not suspicious of this client but am making
this report anyway'.
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Details of secondary individuals associated with the transaction.
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Can only break client confidentiality with a suspicion.
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Incomplete reasons for suspicion i.e. 'Cash transaction £7,000'.
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What is the suspicion? Cash is not suspicious in itself, but is merely an
indicator; Look to what you know about the client, reasons for cash etc; What
type of business are you conducting for your client?
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Incomplete reasons for suspicion i.e.: 'Account/Business/Purchase, is not being
conducted in the expected manner'.
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What is the usual manner? - detail this in your report; Why is this unusual?
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Consent box not ticked on report form.
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Fax front sheet or 'reasons for suspicion' has no mention of consent.
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Submitting late to obtain consent near a deadline, when its clear from the text
that suspicion had been identified at an early stage.
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No information as to why consent required i.e.: entering into an arrangement,
facilitation, concealing, etc.
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