In November 2020 the UK’s Financial Intelligence Unit (UKFIU) within the National Crime Agency (NCA) published its Suspicious Activity Reports (SAR) Annual Report 2020 (here) covering the period April 2019 to March 2020.
The report indicates a continued increase in SARs submitted to the NCA (a 20% increase from the previous period). In addition, similar trends were observed in requests for Defence Against Money Laundering (DAML), which resulted in almost £172m worth of funds being withheld from suspected criminals throughout the period.
The UKFIU has sought to capitalise on these volume increases in both SARs and DAMLs to benefit both existing and new law enforcement investigations. In particular, various SAR working groups have been operationalised to focus on emerging developments within the financial sector. In addition, in response to the Covid-19 pandemic, the UKFIU used SAR reporting output to generate and circulate a regular bulletin articulating key themes and trends stemming from Covid-19-reated criminal activity.
Whilst these continued efforts are important, the UKFIU acknowledges the criticality of the UK’s ongoing SARs Reform Programme which is being led by the Home Office. This programme aims to overhaul the existing SAR process and tackle a variety of challenges involved in the investigation process, including: the quality and usability of SARs and DAMLs submitted, the IT infrastructure in place to process increasing volumes; and the knowledge and expertise of those individuals performing investigations.
Whilst the SARs Reform Programme is ongoing, the UKFIU acknowledge that shorter term solutions are required to cope with the expected continual rise in both SARs and DAMLs into the 2020/21 period. The UKFIU will therefore commence its migration towards a new Target Operating Model (TOM) which aims to be more intelligence-led and strategically focussed to take stepwise action to enhance the SAR and DAML process.