Suspicious activity report

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Suspicious activity report

SARAlso called suspicious transaction report, STR

Definition

A suspicious activity report is a confidential filing a regulated firm makes to its national financial intelligence unit when it knows or suspects money laundering, terrorist financing or other financial crime. In the US it goes to FinCEN, in the UK to the National Crime Agency. Firms must not tell the customer a report has been made.

01 ALERT02 INVESTIGATION03 MLRO DECISION04 SAR FILED
Fig. 1 · Suspicious activity report
31 CFR 1020.320 · POCA 2002 Part 7 · AMLR Article 69
Key rules31 CFR 1020.320 · POCA 2002 Part 7 · AMLR Article 69
Applies toUS banks
RegionsUK · EU · US · Global
01

How it works

Most reports start as alerts from transaction monitoring, staff referrals or screening. Investigators review the activity, gather customer and transaction data and decide whether suspicion exists. In the UK the nominated officer or MLRO decides whether to report. US banks must file within 30 calendar days of initial detection, extended to no more than 60 days when no suspect is identified. Firms keep the report and supporting records confidential.

Reports give law enforcement intelligence it cannot gather elsewhere, and they feed investigations, asset recovery and typology work. Failure to report is a criminal offence in the UK and a common basis for enforcement in the US. Supervisors look at report quality, timeliness and the link between monitoring alerts and filings. Tipping off the customer is itself an offence.

Step 1DetectAlerts, referrals or screening flag unusual activity.
Step 2InvestigateAnalysts review the customer, transactions and context.
Step 3DecideThe MLRO or SAR team decides whether suspicion exists.
Step 4FileSubmit the report to the FIU within the deadline.
Step 5Follow upApply risk-based controls to the customer relationship.
02

The rules

US · 1 April 1996, recodified 1 March 201131 CFR 1020.320Bank Secrecy Act regulations: Reports by banks of suspicious transactions, 31 CFR 1020.320

Requires banks to report suspicious transactions involving at least $5,000, generally within 30 calendar days of initial detection.

US banks
UK · 24 February 2003POCA 2002 Part 7Proceeds of Crime Act 2002, Part 7 (money laundering offences and disclosures)

Makes failure to disclose knowledge or suspicion of money laundering an offence and provides for disclosures to the National Crime Agency.

Regulated sector firms and their staff
EU · 10 July 2027AMLR Article 69Regulation (EU) 2024/1624 (AMLR), Article 69 reporting of suspicions

Requires obliged entities to report suspicious transactions and activity to the national FIU, replacing the reporting rules of the fourth AML directive.

EU obliged entities
03

Common questions

Is a SAR the same as an STR?

They are the same concept. The US and UK use suspicious activity report. Many other jurisdictions, including EU member states, use suspicious transaction report. Both are filed with the national financial intelligence unit.

Does filing a SAR mean the customer is guilty?

No. A SAR records suspicion, not proof of a crime. It is intelligence for law enforcement. Many reports never lead to an investigation, but they can contribute to wider cases and typology analysis.

Can a firm tell a customer it has filed a SAR?

No. Disclosing a SAR, or an investigation, to the customer or anyone else in a way that could prejudice an investigation is prohibited. In the UK this is the tipping off offence; US rules require SAR confidentiality.

What changed in US SAR rules in October 2025?

FinCEN issued FAQs stating firms are not required to run a separate review after filing a SAR to check whether activity continued. They may rely on risk-based policies. The FAQs did not change the filing deadlines.