Accountants advised on how to write better SARsby
The NCA and OPBAS have published guidance for accountants on preparing "clear and concise" Suspicious Activity Reports (SAR). David Winch summarises what a ‘good quality’ SAR looks like.
Not the most snappy title, but the latest “Guidance for anti-money laundering supervisors on submitting better quality Suspicious Activity Reports” published this month is mercifully brief and readable.
It’s been prepared by the National Crime Agency (NCA) in conjunction with the Office for Professional Body Anti-Money Laundering Supervision (OPBAS) with the intention of helping accountants and lawyers improve the quality of the SARs which they submit.
Clear and concise
It’s not rocket science. The key point is that your SAR is going to be read initially by someone who knows nothing about your firm, nothing about the person about whom you are reporting, nothing about what you are hoping or expecting the authorities might do after receiving your SAR and – let’s be frank – probably understands very little about accounts, tax or company law.
It’s likely for this reason that acronyms and jargon should be avoided as the recipient might not understand and they’re open to misinterpretation.
So you need to give them enough background to understand who you suspect, what you suspect them of having done (or failed to do), what your connection is to the suspected person and suspicious events, and why this is an issue which should interest the authorities.
Aside from the most basic advice – “Punctuation should be used” – and please DON’T HIT CAPS LOCK – the guidance asks that SARs be clear and concise and structured in a logical format.
A brief chronological summary of events will be useful and the SAR glossary codes can save time for the writer as well as the reader. A quick XXF4XX tells the reader immediately that you are reporting a suspicion of personal tax evasion.
Of course you will not be in a position to, for example, quantify the amount involved in a suspected fraud – but you probably can give an order of magnitude which gives the reader a better understanding of the issue. The more focussed and relevant information you can supply, the better.
Reason for suspicion
The suspicion element needs to be explicit. But with characters limited (8,000 characters on SAR Online and 30,000 using email bulk encryption), it advises you to focus on the five Ws: who, what, where, when and why.
- Who is involved?
- How are they involved?
- What is the criminal property?
- Where is the criminal property?
- When did the circumstances arise?
- Why is there suspicion?
Then get that SAR submitted and get back to remunerative work!
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David Winch B.Com, F.C.A. has had over 30 years experience in accountancy, audit and tax matters with a wide variety of firms and their clients ranging from the smallest to major multi-nationals. David is a director of MLRO Support Ltd http://www.MLROsupport.co.uk a company which offers...