The National Crime Agency (NCA) has published an updated SARs Reporter Booklet (June 2026). Whilst much of the guidance reinforces existing good practice, it contains a number of practical reminders that every MLRO and fee earner should keep in mind when deciding whether to submit a Suspicious Activity Report (SAR).
1. A good SAR tells a clear story
The NCA again emphasises that investigators should be able to understand who, what, when, where, why and how simply by reading the SAR.
Avoid lengthy narratives containing unnecessary background information. Instead, explain clearly:
- what has caused your suspicion;
- how the transaction or activity fits into that suspicion; and
- why you believe criminal property may be involved.
2. Explain why you are suspicious
Simply describing unusual activity is not enough.
The NCA stresses that reporters should explain the reasoning behind their suspicion rather than expecting investigators to draw their own conclusions. A concise explanation of the red flags is far more valuable than a lengthy description of events.
3. Include all relevant identifiers
A SAR is only as useful as the information it contains.
Where known, include details such as:
- full names and aliases;
- dates of birth;
- addresses;
- bank account details;
- company numbers;
- passport or driving licence details;
- vehicle registrations; and
- crypto wallet addresses where relevant.
The more accurately subjects can be identified, the more useful the SAR becomes.
4. Use glossary codes correctly
The booklet continues to emphasise the importance of using the appropriate glossary codes.
These enable the NCA to identify priority intelligence quickly and ensure SARs are directed to the correct operational teams. Incorrect or missing codes can delay the use of the intelligence you submit.
5. DAML requests require careful drafting
Where a Defence Against Money Laundering (DAML) is required, ensure the request clearly identifies:
- the prohibited act;
- the property involved;
- the value of the transaction; and
- precisely what you are seeking consent to do.
Incomplete DAML requests can delay consideration and may result in further enquiries.
6. Quality matters more than quantity
One of the recurring themes throughout the booklet is that a well-written SAR is significantly more valuable than a poorly drafted report containing excessive information.
Providing relevant, concise intelligence enables law enforcement to assess reports more quickly and link them with intelligence from other sources.
Practical reminder for law firms
For solicitors the booklet is a timely reminder that submitting a SAR is not simply an administrative exercise. The quality of the report can directly affect its value to law enforcement.
MLROs may wish to review their firm’s internal SAR reporting procedures and provide refresher training to fee earners on:
- recognising and documenting suspicion;
- recording the rationale behind decisions;
- gathering sufficient identifying information; and
- drafting concise, intelligence-led SARs.
Small improvements in the quality of internal reports often translate into significantly better external SARs.
The NCA’s SARs Reporter Booklet (June 2026) is well worth reading for anyone involved in AML compliance or acting as an MLRO. Even experienced reporters are likely to find useful drafting tips and reminders that can improve the quality and effectiveness of future SAR submissions.
