SAR Decision-Making & Documentation Toolkit

Every SAR decision you make carries personal criminal liability under POCA. Every decision you don't document properly is a risk you can't defend.

If you're an MLRO or Nominated Officer, you already know the pressure. Internal reports land on your desk. You assess them. You decide whether to submit to the NCA or not. But can you prove — with documented reasoning — that every decision you've made is defensible?

That's exactly what this toolkit gives you!

What's Inside

This comprehensive toolkit provides a complete SAR management framework built on current UK legislation (POCA 2002, Terrorism Act 2000, MLRs 2017), JMLSG Chapter 6 guidance, and FCA Financial Crime Guide expectations.

The Five-Stage SAR Decision Process — A structured methodology that takes you from receipt of an internal report through to post-decision actions, with clear assessment criteria at every stage.

Suspicion Threshold Guidance — Detailed analysis of the Da Silva test, the distinction between knowledge, suspicion, and reasonable grounds for suspicion, with practical application guidance drawn from UK case law including K Ltd v NCA and Shah v HSBC.

Consent SAR (DAML) Framework — Step-by-step guidance on managing the 7 working day notice period, 31 calendar day moratorium, and customer communications during consent — one of the most operationally challenging aspects of the SAR regime.

Tipping Off Prevention — A practical risk matrix covering high-risk and lower-risk scenarios, statutory defences, and prevention measures your team can implement immediately.

Ready-to-Use Templates

• Internal SAR Form — Structured template for staff to report suspicious activity to the Nominated Officer, covering subject details, transaction information, and reporter declaration
• SAR Decision Log — Complete audit trail for all SAR decisions, including non-submissions
• SAR Quality Assurance Checklist — 17-point pre-submission review covering completeness, accuracy, and NCA requirements
• Consent SAR Tracking Register — Timeline tracker for DAML requests, notice periods, moratorium dates, and NCA responses
• Board and Senior Management Reporting Template — Structured format covering summary statistics, key themes, notable cases, and recommendations
• Annual SAR Regime Self-Assessment — 15-point assessment framework to evaluate your firm's SAR processes against regulatory expectations

Practical Case Studies

Three fully worked case studies applying the five-stage framework to real-world scenarios:

• Unusual Cash Deposits — Retail investment client with structured deposits inconsistent with profile (SAR submitted)
• Corporate Consent SAR — Live transaction requiring DAML with a newly established overseas beneficiary (consent SAR submitted)
• Documented Non-Submission — Wealth management client with a legitimate overseas property purchase that triggered an alert (no SAR, fully documented reasoning)

Each case study walks through every stage of the decision process, demonstrating exactly how to document your reasoning — whether you submit or not.

Comprehensive Red Flag Reference Guide

Over 40 red flag indicators organised across five categories: customer behaviour, transaction patterns, account and product usage, geographic and jurisdictional risks, and digital and technology indicators.

Record-Keeping Requirements

Clear guidance on minimum retention periods under MLRs 2017 Regulation 40, practical storage and access controls, and tipping off considerations for record management.

Who This Toolkit Is For

• Money Laundering Reporting Officers (MLROs)
• Nominated Officers under POCA/TACT
• Deputy MLROs
• Compliance Officers with SAR responsibilities
• Senior Managers with financial crime oversight (SMF16, SMF17)
• Compliance consultants advising FCA-regulated firms

Why This Toolkit

The SAR regime doesn't just require you to make the right decision — it requires you to prove you made a reasonable decision, properly considered, and fully documented. Whether you submit a SAR or decide not to, your file needs to demonstrate that you applied a structured framework and reached an informed conclusion.

This toolkit gives you that framework. Ready to use. Fully customisable Templates (duplicated as Word Docs. Built for the real world of UK financial crime compliance.

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