The National Crime Agency (NCA) has published its Suspicious Activity Reports (SARs) Annual Report 2019. The report shows that the number of SARs has continued to increase; an issue that prompted the Law Commission to propose a series of reforms to the SAR regime earlier this year.
There has been a 3% increase in the number of SARs received between April 2018 and March 2019, with over 478,000 SARs received. Notably, the number of Defence Against Money Laundering (DAML) SARs (i.e. consent SARs) increased by over 50%.
The amount of money denied to criminals also significantly increased; over £131m was restrained following refused DAML SARs, representing a 153% increase. The reason for the increase in the amount of restrained funds is believed to be the introduction of Account Freezing Orders and the extension of the moratorium period by the Criminal Finances Act 2017.
The report also notes a change in the pattern of reporting. Reports from lawyers and accountants remain low, but the Financial Intelligence Unit (FIU) is seeing increased reporting from challenger banks and Fintech companies. As a result it plans to expand its understanding of these sectors and undertake targeted outreach to them.
Further changes may be on the cards under the Government’s Economic Crime Plan, which together with the Law Commission Report on the SARs regime sets out various proposed changes to the UK money laundering regime, including amendments to the Proceeds of Crime Act 2002 and guidance on its key provisions.
(This article was written with great assistance from Georgia Austin-Greenall, Trainee Solicitor)