Derrick ponders… Nathan’s nappy

The Shah case [1] reiterated the requirement that suspicious activity reports (SARs) should be made on a timely basis. Some regulated businesses set a time limit for making a SAR – for example, five days – but how long do you have to make your report to the Serious Organised Crime Agency (SOCA)? Derrick Paterson ponders some of the factors that might slow down the process.

The purpose of this article is to pose questions and instigate discussion. It does not represent advice. Derrick Paterson Dip(AML) FCA MICA, is the Director of Ophelimity Limited, an independent AML consultancy. He may be reached on +44 (0) 77 0000 6986, derrick.paterson@hotmail.co.uk

A SAR might go through the following stages (which does not take into account the requirement for consent - where the need for speed will be even greater):