Module 4 · Chapter 8

Suspicious Activity Reports (SARs) and DAML Requests

When the firm’s reporting officer suspects laundering, he must tell the authorities. This chapter shows how that report works, and why the firm asks for a defence before the deal moves.

≈ 8 min read 8-question test

In this chapter

  • What the MLRO can do with your internal report
  • Why the firm asks for a defence before it acts
  • What happens when the NCA refuses, and when it stays silent

8.1Reporting to the NCA in one paragraph

Your internal report goes to Julian, the firm’s MLRO. Only he decides what the NCA is told. If he suspects laundering, he must send it a SAR.

Here the firm is also about to act. It wants to exchange, complete or send money back, and each step could help launder the money. So the SAR also asks for a defence, which protects the firm’s people if they go ahead. If no refusal comes within seven working days, the firm has one.

Key point

Report first, then act. Nothing moves on the named steps until the firm has its defence.

Also in this chapter

  1. The MLRO’s three choices
  2. Why privilege does not stop the report
  3. Why the firm asks for a defence before exchange
  4. Deemed consent: what the NCA’s silence means
  5. Your job

Preview

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