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ARTICLE · 17 JULY 2019

W.I.R.E Debates: Law Commission Proposals On Suspicious Activity Reporting

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The primary aim of the Law Commission's report was to address systemic problems in the SAR process to ensure that it is proportionate and efficient.

United KingdomGovernment, Public Sector
Lloyd Firth
Lloyd Firth
Frederick Saugman
Frederick Saugman
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An earlier version of this article was published by Thomson Reuters on 8 July 2019. 

The UK Law Commission has published a report1 criticising existing anti-money laundering legislation and providing recommendations to improve the quality of Suspicious Activity Reports (SARs).  What should we make of these recommendations, and do they go far enough?  Fred Saugman and Lloyd Firth present their views.

The background

The SAR regime is designed to be one of the UK's chief AML tools, providing intelligence about suspected money laundering to law enforcement agencies and shielding the reporting entities from criminal liability. It operates by way of required disclosures (those operating in the regulated sector are obliged to raise suspicions about potential money laundering, with a failure to do so a criminal offence) and authorised disclosures (individuals who suspect they are dealing with the proceeds of crime can seek consent to complete a transaction by

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