Defence against money laundering
DAMLAlso called consent SAR, appropriate consent
A defence against money laundering, or DAML, is a request to the UK National Crime Agency for consent to carry out an act that may involve criminal property. A firm files it as a suspicious activity report. If the agency does not refuse within seven working days, the firm has a defence to the principal money laundering offences.
How it works
A firm that suspects funds are criminal property and wants to process them files a DAML request through the SAR portal. It then waits. The NCA has seven working days to respond. Silence counts as consent. A refusal starts a 31 day moratorium, which a court can extend in steps of up to 31 days, adding no more than 186 days in total.
DAMLs let firms avoid committing a money laundering offence while dealing with suspect funds. They also give law enforcement time to restrain assets. The cost is delay to customers and tipping off risk during the wait. In 2023 the law added an exemption for returning funds when exiting a customer, now set at £3,000.
The rules
Sets out appropriate consent and authorised disclosures, with a seven working day notice period and 31 day moratorium after refusal.
Anyone making an authorised disclosure, mainly regulated firmsLets the Crown Court extend the moratorium period by up to 31 days at a time, to a maximum of 186 days.
Firms awaiting a DAML decisionRaises the section 339A threshold amounts from £1,000 to £3,000 for operating accounts and for returning funds when ending a customer relationship.
Deposit-taking bodies and other regulated sector firmsCommon questions
How long does a DAML take?
The NCA has a notice period of seven working days starting the day after the request. If it refuses, a 31 day moratorium follows. A court can extend the moratorium in steps of up to 31 days, adding no more than 186 days in total.
Is a DAML the same as consent?
Yes in substance. The legislation calls it appropriate consent. The NCA uses the term defence against money laundering because consent does not mean approval of the transaction. It gives the reporter a defence to the principal money laundering offences.
Does every suspicious payment need a DAML?
No. A DAML is needed only when a firm plans to do something with property it suspects is criminal. Deposit-takers and other regulated firms have threshold exemptions, raised to £3,000 in July 2025, for some account operations and customer exits.
