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SAR Quality issues

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.
Significant omissions might include:
  • 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).
  • No occupation / employer.
  • No reasons for suspicion i.e. 'I am not suspicious of this client but am making this report anyway'.
  • Details of secondary individuals associated with the transaction.
    • Can only break client confidentiality with a suspicion.
  • Incomplete reasons for suspicion i.e. 'Cash transaction £7,000'.
    • 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?
  • Incomplete reasons for suspicion i.e.: 'Account/Business/Purchase, is not being conducted in the expected manner'.
    • What is the usual manner? - detail this in your report; Why is this unusual?
  • Consent box not ticked on report form.
  • Fax front sheet or 'reasons for suspicion' has no mention of consent.
  • Submitting late to obtain consent near a deadline, when its clear from the text that suspicion had been identified at an early stage.
  • No information as to why consent required i.e.: entering into an arrangement, facilitation, concealing, etc.

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