The National Crime Agency (NCA), through its UK Financial Intelligence Unit (UKFIU), has published updated guidance on Suspicious Activity Reports (SARs) and Defence Against Money Laundering/Terrorist Financing (DAML/TF) requests.
The new guidance has been compiled in an accessible and definitive set of chapters replacing the previous guidance and FAQ documents, which have now been withdrawn.
The purpose? To give reporters a single, authoritative resource to cut through confusion which has persisted over time.
Following on from his article on the impact ECCTA had on the SARs regime, Paul Chadwick looks at the new guidance, its purpose, and its implications for regulated firms.
Inside the guidance
The guidance is structured around three core chapters:
- Using the SAR portal – which includes step-by-step instructions for registering, uploading, and navigating the reporting system.
- Submitting a SAR – which includes practical tips on what to include, how to frame suspicion, and common pitfalls to avoid.
- Understanding DAMLs and DATFs – which includes clear explanations of how to request a defence, and when such requests are appropriate.
By resetting the guidance this way, the SARs regime is also being repositioned away from being a compliance burden and championed as a vital intelligence pipeline for investigators who rely on it.
The guidance is designed to improve SAR consistency and quality but to also ensure law enforcement agencies can use and receive actionable intelligence, rather than vague or uninformed data.
Why the change matters
Better reports and clarifying related processes should mean shorter (and less stressful) delays in transactions where a defence is needed.
But SAR reporters have also often previously complained of not knowing how their reports were received and of being left in the dark–unsure if their reports were useful, if they included the correct detail or what happened afterwards.
The new guidance directly addresses these concerns and expectations, clarifying law enforcement requirements, sharing best practice examples, and highlighting the value of SARs in disrupting crime.
As set out in resources on our ECCTA hub, that legislation is a call to arms for businesses to tackle financial crime nearer the source. Here the NCA echoes this and encourages reporters to see themselves as partners in crime prevention and to embed SARs into the broader risk management culture of firms across the regulated sector.
Practical implications for reporters and looking ahead
For compliance teams, MLROs, and practitioners, the key takeaways are:
- Consistency is king – the guidance sets out what a good SAR looks like and should contain.
- Be proficient in using the portal – get registered and trained, get using the glossary codes if you can.
- Strategic use of DAMLs – think carefully about when to request a defence, know what’s your decision to make.
The updated guidance reiterates how proactive SAR reporters make valuable contributions to national security and financial integrity. By consolidating and modernising the rules, the NCA has made it easier for reporters to do their job well.
For regulated firms, the bottom line is simple: embrace the guidance, train your teams, and see SARs not as a burden but as a badge of responsible practice.
How can we help?
If your organisation needs tailored advice on SARs or ECCTA compliance, or expert support with strengthening AML procedures, our team can provide the guidance you need. Contact us to find out more.
