Suspicious Activity Reporting (SAR) Procedure
1. Purpose
This procedure (Ref: COMP-AML-002) sets out the process for reporting suspicious activity internally and, where required, externally to the relevant Financial Intelligence Unit (FIU). It supports the Bank's obligations under AMLD6, the Proceeds of Crime Act 2002, and applicable national AML legislation.
2. Scope
This procedure applies to all employees, temporary staff, contractors, and third-party agents of the Bank. Failure to report known or suspected money laundering or terrorist financing activity is a criminal offence in most jurisdictions in which the Bank operates.
3. What Constitutes Suspicious Activity
Suspicion may arise from any of the following, among other indicators:
- Transactions that have no apparent economic or lawful purpose.
- Transactions inconsistent with the customer's known profile, business, or risk rating.
- Unusual patterns of activity, including structuring (splitting transactions to avoid reporting thresholds).
- Reluctance by a customer to provide identification or documentation.
- Transactions involving high-risk jurisdictions identified by the FATF or the Bank's internal risk assessment.
- Adverse media or negative screening results linked to a customer or counterparty.
4. Internal Reporting Procedure
Step 1 — Identification
Any employee who forms a suspicion, or who has reasonable grounds to suspect that a transaction or business relationship is connected to money laundering or terrorist financing, must not proceed with the transaction (unless instructed by the MLRO) and must not disclose the suspicion to the customer ("tipping off").
Step 2 — Internal SAR Submission
The employee must complete an Internal SAR Form via the Bank's compliance reporting portal within 24 hours of the suspicion arising. The form requires:
- Customer name, account number, and relationship details.
- Description of the suspicious activity or transaction.
- Supporting documentation (transaction records, correspondence, screening results).
- The employee's assessment of why the activity is suspicious.
Step 3 — MLRO Review
The MLRO (or Deputy MLRO) will review the internal SAR within two (2) business days of receipt. The MLRO will determine one of the following outcomes:
| Outcome | Action |
|---|---|
| File External SAR | The MLRO submits a report to the relevant FIU and records consent status. |
| Request Further Information | The MLRO requests additional details from the reporting employee or the AML Unit. |
| Close — No Further Action | The MLRO documents the rationale for closure. The record is retained for audit purposes. |
Step 4 — Consent Regime
Where a SAR is filed externally and relates to a pending transaction, the Bank must obtain consent from the FIU before proceeding. If no response is received within the statutory moratorium period (typically seven (7) working days under POCA, or as defined by local legislation), the Bank may proceed with the transaction unless a further moratorium is imposed.
Step 5 — Record Keeping
All internal and external SARs, supporting documentation, and MLRO decision records must be retained for a minimum of five (5) years from the date of filing.
5. Escalation and Timelines
| Event | Timeline | Responsible Party |
|---|---|---|
| Suspicion identified | Immediately — do not proceed with transaction | All employees |
| Internal SAR submitted | Within 24 hours of suspicion | Reporting employee |
| MLRO initial review | Within 2 business days | MLRO / Deputy MLRO |
| External SAR filed (if required) | Within 3 business days of MLRO decision | MLRO |
6. Confidentiality and Tipping Off
Employees must not disclose to the customer, or any third party, that a SAR has been filed or is being considered. Tipping off is a criminal offence and may result in disciplinary action up to and including termination, as well as criminal prosecution.
7. Review
This procedure is reviewed annually by the AML Unit and approved by the Group CCO. The next review is scheduled for Q2 2027.