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Accountants advised on how to write better SARs


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. 

29th Mar 2021
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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?

If you’re needing to submit a SAR have a read of this new guidance HERE and use the appropriate glossary codes which you can find HERE.

Then get that SAR submitted and get back to remunerative work!


Replies (13)

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By Open all hours
29th Mar 2021 17:36

Never mind being lectured on the quality of the writing. Have been clear, concise, detailed and accurate I have no evidence whatsoever that any of the SAR reports I have submitted have even been read.

Thanks (2)
Jennifer Adams
By Jennifer Adams
29th Mar 2021 18:18

A couple of years ago (Jan 2019) a member commented that he had submitted SARS and found that they were being ignored by HMRC such that he couldnt be bothered anymore having other things to do.

From his comment this article was written:

"Should you bother to submit a SARS?"

As new guidelines have been issued does that mean HMRC will take a little more interest in what accountants are reporting?

Thanks (1)
By Roland195
29th Mar 2021 20:52

So if the NCA are unable to act on the information we supply because they can't understand what we are driving at with our tax jargon and accounting gibberish then why the hell are we reporting it to them in the first place?

Nothing at all to do with the fact that somewhat meaningful reports by accountants are swamped by drivel from banks?

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By ireallyshouldknowthisbut
30th Mar 2021 10:09

I have gifted HMRC two very significant opportunities in the past 2 years to collect in one case over £20k and in the other over £30k.

HMRC response...............nothing. I am sure in both cases I would have heard about it as the ex-clients would have needed to contact me to get some of the data.

I fill 'em in, but it would be nice if some action was taken or it becomes a very pefunctionaty excise on my side to just bang something in to cover my risk.

When accountants are filing them its hardly going to be for fun or because the tax is not due, we do it as people are knowingly (after we have told them about it) not paying their taxes.

Thanks (1)
Replying to ireallyshouldknowthisbut:
By Roland195
30th Mar 2021 10:24

Is this not what this article is saying though - the reports are not made to HMRC but to the NCA who can't make head nor tail of them so chuck them under a hedge.

Can they not at least have some HMRC staff seconded there?

Thanks (1)
Replying to Roland195:
By ireallyshouldknowthisbut
31st Mar 2021 14:06

I can assure you both reports were written assuming an outsourced £3 an hour employee who know nothing about anything.

Either HMRC are not getting the reports, or they are getting them but not acting on them.

its a disgrace either option.

Thanks (0)
By tedbuck
30th Mar 2021 11:18

My own guess is that seconding HMRC staff would make absolutely no difference as they are, it seems, mostly tax geared and don't understand accounts. In the good old days ( Acronym not permitted) when tax offices were local and the people could see the businesses they dealt with it was rather better but experience with the very occasional enquiry in recent years suggests that understanding of the finer points of accounts just isn't there so even if HMRC were involved it would not make a huge difference.
We had occasion to report the tip of a potentially large iceberg about a year ago but the silence was absolutely deafening. As has been suggested by others it all seems pretty much a waste of everyone's time but I suppose like GDPR etc it gives HMG a reason to raise money by exhorbitant fines rather than taxes so that they can smirk about how good they are at protecting the public. Yuk!

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By North East Accountant
30th Mar 2021 13:03

Great article David and sage advice as normal.

Not your fault but bloody frustrating that the Government and HMRC has no real intention of tackling fraud or tax fiddling etc

They talk a good game but actions speak louder than words, and it just isn't happening.

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By JamesDS
30th Mar 2021 16:17

That's only 4 Ws. You missed Why.
Sorry, my OCD threshold got tripped!

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By AndrewV12
31st Mar 2021 09:43

The Government and HMRC should concentrate on giving covid related grants (50K) to those who have a reasonable cancel of repaying them, or even better don't give out the 50K grants at all, they will never receive anything like 50K back, particularly Limited Company's.

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By Ian McTernan CTA
31st Mar 2021 14:17

If they gave some feedback on the success of these it might encourage people to believe they make any difference at all. Even a small release saying 'as a result of reports submitted by accountants £Xbn of additional taxes were recovered' (I expect the actual figure to be £x thousand...)
I'm lucky that in my very small client base I've never had to do a report.
Telling us how to write them better is a complete waste of space- pretty much like the whole AML system which surely costs much more than it ever tracks down, as has just become another huge employment/paperwork triangle.
Want to catch more people? Employ us accountants on secondment as consultants and scrap the entire AML and pay us that instead- guaranteed to yield much more and to be less of a headache to everyone involved.

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By BillKate
01st Apr 2021 17:56

Thank you for the article David.
Am I the only one struck by the irony of the situation - As potential report writers, we must use very simple language with no complicated jargon so that the report can be understood. However, we also need to master a list of complicated jargon sounding codes to use within our reports so that the reader can understand what we are reporting!
'XXF4XX tells the reader immediately ... ' that's good to know as it means sweet XX to me!

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By Monty785
08th Apr 2021 11:43

The report should clear, concise, logical, including all relevant and supporting documentation. In order to make it easier to read and understand, avoid using acronymns and jargon and writing in bold or capital letters. If a large amount of text is being submitted, break it up with paragraphs and use punctuation.

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