Tell us about suspicious activity that may be linked to money laundering
Find out how and when to report suspicious activity to the National Crime Agency or HMRC.
Suspicious activity or transactions
There are many reasons why you or one of your employees might become suspicious about a transaction or activity. Often it’s just because it’s something unusual for your business, for example:
- a customer has tried to make an exceptionally large cash payment
- the customer behaved strangely, or made unusual requests that did not seem to make sense
- the transaction they wanted to make just did not add up commercially
You must look carefully at all transactions to see if there’s anything suspicious about them.
You can find more guidance on the main indicators of suspicious transactions for:
- money service businesses
- high value dealers
- trust or company service providers
- estate agency businesses
- accountancy service providers
- art market participants
You must try to identify any activity linked to money laundering or terrorist financing, for all parts of your business.
If you know about or suspect money laundering or terrorist financing you must consider telling either:
- the National Crime Agency (NCA)
- HMRC Fraud Hotline
You also must consider whether you need NCA consent before you proceed with a suspicious transaction. The NCA will tell you if you’re granted a defence against money laundering charges.
If your business is registered for money laundering supervision
Anyone in your business must report any suspicious transaction or activity they become aware of to the nominated officer. It’s the nominated officer’s responsibility to decide whether they need to send a report or ‘disclosure’ about the incident to the NCA. They do this by making a Suspicious Activity Report (SAR).
The nominated officer must normally suspend the transaction if they suspect money laundering or terrorist financing. If it’s not practical or safe to suspend the transaction, they should make the report as soon as possible after the transaction is completed.
The NCA receives and analyses SARs and uses them to identify the proceeds of crime. It counters money laundering and terrorism by passing on important information to law enforcement agencies so they can take action.
Submitting a Suspicious Activity Report to National Crime Agency
You or your nominated officer can send the report online on the NCA website.
You must consider whether you need a defence against money laundering charges from the NCA before you can proceed with a suspicious transaction or activity.
You’ll find out if the NCA have granted a defence when they reply to your SAR.
If you do not get a reply from the NCA within 7 working days and think you’ve correctly reported the activity, you can choose to assume a defence is granted.
If you get a reply that says you do not have permission to proceed, the NCA have a further 31 calendar days to take action.
If you’ve not heard from the NCA after the 31 days, you can proceed if you want to. You will not be committing an offence.
The 31 day period does not apply to terrorist financing cases, you will not have a defence until the NCA grants your request.
If your business is not registered for money laundering supervision
You should send a report to the HMRC Fraud Hotline if:
- your business is not registered for money laundering supervision
- you need to report breaches of the money laundering regulations
- you need to report a business that should be registered with HMRC but is not
Last updated 4 August 2021 + show all updates
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A link to Art market participants guidance for money laundering supervision has been added.
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This guide has been updated to reflect changes to legislation from 26 June 2017, including how to send a Suspicious Activity Report to the National Crime Agency and proceed with a suspicious activity or transaction.
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First published.