Who Expects What From Your SARs: The NCA, the FCA, JMLSG and the Law
UK AML and Europe: Who Expects What From Your Suspicious Activity Reports Ask four people in a financial crime team who sets the standard for a SAR and you may get four different answers. The law, the NCA, the FCA and the industry guidance each play a part, and they do different jobs. In short: the law creates the duty, the NCA receives and uses the reports, supervisors check your systems, and industry guidance shows what good looks like. Who What they do for your SARs The law SARs come from section 330 of the Proceeds of Crime Act 2002, not from the 2017 Money Laundering Regulations. The Regulations require a nominated officer and procedures. The NCA Receives reports through the UKFIU, publishes guidance and decides what to do with what it receives. The FCA Supervises the systems and controls of the firms it regulates, including how they identify and escalate suspicion. JMLSG Publishes industry guidance for the financial sector that supervisors generally treat as a ben...