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MLROs to have improperly completed SARs rejected under new consent regime
24 September 2014

From 1st October 2014, Money Laundering Reporting Officers (MLROs) who fail to complete consent suspicious activity reports (SARs) properly, will have them rejected under new guidance issued by the National Crime Agency. SARs disclosures which omitted either the reason for suspicion or a statement regarding the criminal property involved, would in effect be rejected, or “closed”. The SARs reporter would then be sent a notification letter stating that the submission had been closed. Despite this, MLROs would still have a legal obligation to make a disclosure before the “prohibited act” took place, and to obtain consent to avoid any liability under the Proceeds of Crime Act 2002 (PoCA). It is recommended that firms use SAR Online when submitting a consent request as this will prompt for certain relevant information. Firms should also ensure that the contact details held by the NCA for the appropriate individual at the firm are up to date, especially if they have not submitted a SAR for some time. For further guidance click here.

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