HOW TO COMPLETE A SUSPICIOUS ACTIVITY REPORT (SAR)

Transcription

1 HOW TO COMPLETE A SUSPICIOUS ACTIVITY REPORT (SAR) Accommodation Addresses Business Centres Coworking Space & Hubs Light Industrial Space Mail Forwarding Managed Workspace Serviced Offices Studios Virtual Office Providers Operation Sterling is a Metropolitan Police Service initiative dedicated to proactively preventing fraud and works in close partnership with the Virtual Office Forum and the BCA to support and promote best practice and due diligence. Next page Close Print VIRTUAL OFFICE FORUM DEC 2011

2 VIRTUAL OFFICE FORUM HOW TO COMPLETE A SUSPICIOUS ACTIVITY REPORT (SAR) CONTENTS How to report a Suspicious Activity Report (SAR) 3 Guidance notes on completing a SAR 5 Questions 10 Previous page Close Next page Print 2

3 How to report a Suspicious Activity Report (SAR) You and your staff are under a legal obligation to report any suspicious activity. Before you can start reporting SARs you need to register on the SOCA website. This is a very easy and quick process. Go to click on Reporting SARs in the top right hand corner. The following page will appear and explain about the online system. Please read through this information before proceeding to register. You will then be asked to add/register all of your details. Once you have submitted your registration you will be provided with two activation codes. The first within your online session, the second by to your unique user address. You should expect this by return. If you have not received this within four hours then the process may have failed for one of the following reasons: You have used an incorrect address Your organisations own firewalls may be preventing its delivery There is temporarily a large amount of traffic on the site Once you ve received your second activation code you can go back to the SOCA website and click the activate/reactivate account icon. You will be asked to enter a password and password reminder question. Once you have submitted these details you will be taken to the following screen. To register click on the link at the top right hand side of the screen. This will take you through to the New User registration. Here it will explain what you need to consider before registering. Read through the details on this page and click proceed to registration. You are now ready to report your SAR. Click on the New SAR icon on the left hand side. A SAR consists of five steps. To complete the SAR, move from Step 1 through to Step 5 following the instructions on each page. You must save your entry on each page before you proceed to the next step. Once you have reported your SAR you will receive an , which will include the number on the SAR you submitted, and the unique reference number SOCA allocated on receipt. You should store this carefully along with your record of the information you submitted. At the next page is where you have to enter your address. Complete the details on this page and click Register. 3

4 The following guidance notes are applicable to both manual reporting and electronic SAR online reporting. There are also further Guidance Notes (48.28 kb PDF) for all the available fields. What information should I include in a SAR? SARs provide information and intelligence to Law Enforcement Agencies (LEAs) which help them prevent, detect, investigate and prosecute crimes. The information is predominantly used in relation to financial crime and money laundering but can also be helpful in relation to other criminal activity. The content and quality of a SAR can affect the UK Financial Intelligence Unit s (UKFIU s) ability to prioritise and process the report and LEAs decision or ability to investigate. Often a seemingly irrelevant piece of information can become a valuable piece of intelligence. To make SAR information as useful as possible to Law Enforcement Agencies (LEAs ), try to answer these six basic questions: Who? What? Where? When? How? Why? You may not always have full details concerning the subjects of your reports, especially in circumstances where you are reporting on subjects who are not your clients - customers, suppliers, and so on are all potential SAR subjects as well. The more identifying information and explanation of suspicions provided in a SAR, the greater the likelihood the UKFIU will be able to match the data to other intelligence and put it to active use. Therefore, if possible, please include: Subject s full name, date of birth and address(es), including postcode. Subject details, such as National Insurance numbers, vehicle registration, driving licence, passport, phone numbers, website addresses. Details of occupation/employer. Details of any associates of the subject. Company details, including full legal name and designation, e.g. Limited, plc, or the relevant term if non-uk (SA in Spain, GmbH in Germany etc). Also DHSS registration number (tax reference and VAT number if available), country of incorporation, addresses, phone numbers, addresses, website addresses etc. If appropriate to your business, include the subject s account number/policy numbers and transaction details (including recipient account details). Subject type, e.g. perpetrator, victim, or unknown where their role in the activity is unclear. If consent is required and why, and any deadlines. It is important the relevant information is completed within the appropriate fields, and is not merely placed within the Reasons for Suspicion field. In addition to this information, please include a full reason for your suspicion, providing a concise and focused explanation of why the activity is unusual or suspicious, including: date of activity type of product or service how activity will or has taken place, and the reason for suspicion. Please do not speculate on the offence as this often influences who will investigate the SAR, and can be misleading. Please use plain English and avoid legal, technical or sector specific terms. Example 1: I am not suspicious of this client but I am making this report anyway. There must be a suspicion. Example 2: Cash transaction 7,000. What is the suspicion? Cash on its own is not suspicious, though should be discouraged, but merely an indicator. Look to what you know about the client, reasons for cash etc. What type of business are you conducting for your client? Example 3: Account/Business/Purchase is not being conducted in the usual manner. What is the usual manner? Why is this unusual? It is important the relevant information is completed within the appropriate fields and not merely placed within the 'Reasons for Suspicion' field. There are a number of fields that should be completed in order for a report to be accepted by SOCA. These fields are: Your reference (name/reference) Disclosure type (new or update) Source identity Source outlet identity Today's date (Main subject) surname or company name Reasons for suspicion. 4

5 Guidance notes on completing a SAR The following guidance notes are applicable to both manual reporting and electronic SAR Online reporting. Your ref: The reference number, or alphanumeric identifier, that you allocate to the SAR within your own filing system. Sheet no: The number of pages used to complete the SAR. Disclosure type: This field should contain the type of offence under which you report (i.e. Crime, Drugs or Terrorism). Disclosure date: The date upon which the original report is made within your institution, either New or Update. New is any new suspicious activity or any further activity on a previously reported account/activity or arrangement. Update is any further information that is not a transaction, on a previously reported account/activity or arrangement, e.g. a new address of a subject Existing disclosure ID: If you have entered 'Update' in the previous field, please enter here any reference number SOCA may previously have supplied relating to the subject in question. Constructive trust: Fill this check box if the report relates to an issue of constructive trust. Further information: Filling in this check box indicates that you retain further information relating to the report, which may be of interest to SOCA or another financial investigator. For example, if your disclosure relates to a mortgage application, it may not always be necessary to provide the full documentation. In this case, indicate its existence here and provide a concise description in the 'Reasons for Suspicion' field. Do not send the further information with your form. Source ID: The name of your institution. Source outlet ID: The name (or sort code) of the branch office from which the report originates. Today's date: Date report submitted to SOCA (automatic date field). Main subject (person or company) This information describes the individual (or company) on whom you wish to report. Surname: Subject's family name. Forenames: Subject's forenames. 5

6 Title: Title of subject (Mr, Mrs, Dr etc). Date of birth: Date of birth of subject. Gender: Gender of subject. Occupation: Occupation of subject. Employer: Subject's employer. Or: Company Name: Company name of subject. Company No: Company registration number of subject. Type of business: Type of business of subject. VAT no: VAT number of subject. Country of Registration: Country of registration of subject. Address Number, street, city/town, county, country. Full address of subject. Postcode: Postcode of address of subject. Type: Type of address of subject (i.e. home, accommodation, trading etc). Current: Is the address of the subject current, Yes or No? ID Information: Describes the type of identification offered or taken (e.g. driving licence). Unique information ID: Give details of the identification taken (e.g. driving licence number). 6

7 Extra information/description: Give any further information relating to the identification taken, which may be relevant or of use (e.g. if passport, the country of issue). Other information: Give any further details that help to identify the subject. Disclosed account details: This information describes an account with which the subject or suspicious activity is connected. FI ID: The name of the financial institution that holds the subject's account. Sort Code: The sort code of the branch office that holds the subject's account. Opened: Date account opened. Closed: Date account closed (if applicable). Turn' Cd: Turnover credit. Turn' Db: Turnover debit. Acct. Name: Account name. Acct No: Account number. Acct Bal: Account balance. Bal Date: Date of the balance. Turn Pd: Turnover period. Individual transactions with counterparty account details This section contains details of the transaction, or series of transactions that have aroused your suspicion, and details of the counterparties involved. Date: The date of the transaction. 7

8 Amount: The amount of the transaction. Currency: The currency concerned in the transaction (e.g. GBP, USD, DEM etc). Cr/Db: This field stipulates whether the transaction constitutes a credit or debit in relation to the account identified above. Type: The type of transaction conducted (e.g. cash, cheque, electronic transfer, mortgage etc). Notes: This field is available for further information relating to the transaction identified above. FI ID: The name of the institution that holds the counterparty account, if applicable. Sort Code: The sort code of the branch office that holds the counterparty's account. Acct. Name: The name of the counterparty. Acct. No: The counterparty's account number. Associated subject (person and company) This information describes the person(s) or companies with which the subject or suspicious activity. It is a person or company that is linked to the main person/company in some direct way and is involved in the suspicious activity. Include the financial institution responsible for that account if it is involved in your suspicions. Surname: The associated subject's family name. Forenames: The associated subject's forenames. Title: Title of associated subject (Mr, Mrs, Dr etc). Date of birth: Date of birth of associated subject. Gender: Gender of associated subject. Occupation: Occupation of associated subject. 8

9 Employer: Associated subjects employer. Reason for association: Give details of the connection between the Main Subject and associate subject Or: Company name: The name of the associate company. Company no: Company number of associated subject. Type of business: Type of business of associated subject. VAT no: VAT number of associated subject. Country of registration: Country of registration of associated subject. Reason for association: Give details of the connection between the Main Subject and associate subject Or: (Associated) subject already exists as main subject of a previous report and is provided for use if you have previously reported on the associated subject. Existing disclosure ID: The reference number, which SOCA may have provided in relation to previous reports, relating to the associated subject. Your Ref: The reference number, or alphanumeric identifier, that you allocated within your own file system to the previous report on the associated subject. Reason for association: Details of the connection between the Main Subject and associate subject (Associated subject) address Number, street, city/town, county, country: Full address of associated subject. Post code: Post code of address of associated subject. Type: Type of address of associated subject (i.e. home, accommodation, trading etc). Current: Is the address of the associated subject current, Yes or No. 9

10 (Associated subject) ID information ID information: Describes the type of Identification offered or taken (e.g. driving licence). Unique information ID: Give details of the Identification taken (e.g. driving licence number). Extra information/description: Give any further information relating to the Identification taken, which may be relevant or of use (e.g. if passport, country of origin). General information: Give any further details that help to identify the subject. Reason for disclosure This section requires a clear and thorough explanation of the grounds for your suspicion. Submissions that do not provide reasons for suspicion cannot be accepted as a SAR by the UKFIU. For further information contact the UKFIU SAR Team at PO Box 8000, London, SE11 5EN Questions Please contact your Nominated Officer should you have any questions If you do not have a Nominated Officer contact the BCA for guidance Previous page Close Contents Print 10