Suspicious Activity Report (SAR)

SARs are the primary mechanism through which the private sector alerts authorities to potential financial crime. They are the foundation of the global AML system. Failure to file a SAR when required is a criminal offense in most jurisdictions. Conversely, filing a SAR provides legal protection — organizations cannot be sued for breach of confidentiality when reporting in good faith.

File a SAR when you have reasonable suspicion that a transaction or activity may involve:

• Money laundering — structuring, layering, unusual cash transactions
• Terrorism financing — funds linked to known terrorist organizations or activities
• Fraud — identity fraud, account takeover, payment fraud
• Tax evasion — structuring to avoid tax reporting thresholds
• Bribery and corruption — payments to/from government officials
• Sanctions evasion — circumventing sanctions through intermediaries
• Market abuse — insider trading, market manipulation

• Transactions inconsistent with the customer's profile or stated business
• Structuring — breaking transactions into smaller amounts to avoid reporting thresholds
• Rapid movement of funds through multiple accounts with no clear business purpose
• Reluctance to provide identification or using false documentation
• Transactions involving high-risk jurisdictions without clear business rationale
• Cash-intensive activity disproportionate to the business type
• Third-party funding — someone else paying for another's transactions
• Attempts to avoid record-keeping requirements

1. Detection — frontline staff, transaction monitoring systems, or compliance reviews identify suspicious activity
2. Internal escalation — report to the compliance officer / MLRO (Money Laundering Reporting Officer)
3. Assessment — MLRO evaluates whether reasonable suspicion exists
4. Filing — submit the SAR to the national FIU within required timelines
5. Consent — in some jurisdictions, you must obtain FIU consent before proceeding with the transaction
6. Record keeping — retain the SAR and supporting documentation for at least 5 years

It is a criminal offense to inform the customer (or anyone else) that a SAR has been filed or that an investigation is underway. This includes:

• Telling the customer their transaction is under review
• Asking the customer if they are engaged in money laundering
• Sharing SAR information with colleagues who don't need to know
• Discussing the filing with the customer's other service providers

Jurisdiction	Authority	Format
US	FinCEN	BSA E-Filing, within 30 days
UK	NCA (UKFIU)	SAR Online, before proceeding (consent regime)
EU	National FIUs	Varies by member state
UAE	goAML	UAE FIU electronic system

• EU 6AMLD Article 33 — suspicious transaction reporting obligation
• US Bank Secrecy Act (BSA) — FinCEN SAR filing requirements
• UK Proceeds of Crime Act 2002 — SAR regime and tipping-off offense
• FATF Recommendation 20 — reporting of suspicious transactions