Suspicious activity reports & DAML
The UKFIU reporting route, proposed acts, confidentiality and the limits of a defence.
A suspicious activity report gives the UK Financial Intelligence Unit information about suspected money laundering or terrorist financing. It is a different process from a director conduct report, a sanctions report or a creditor’s proof. The relevant legal reporting duty depends on the facts and the person’s role.
Recognise and escalate
Record the information which gives rise to knowledge or suspicion and follow the appropriate internal reporting route. Separate established facts, explanations and inferences. A missing record or unusual payment may warrant enquiries, but should not be presented as proof of crime.
Use the NCA’s current reporting guidance and the applicable statutory tests. Reporting arrangements must protect confidential information and enable timely consideration of proposed transactions.
Consider the proposed act
Where a proposed act may involve criminal property, consider whether a defence against money laundering is needed before doing it. A DAML request needs to identify the act and the relevant property; it is not a general request to approve an insolvency case.
A defence has a limited statutory effect. It does not validate asset ownership, waive sanctions restrictions or determine whether a transaction is commercially or professionally appropriate. Timing, moratorium provisions and exceptions require the current legal framework.
Technical detail
The POCA reporting provisions and principal offences have different elements. Terrorist financing uses a related but distinct statutory framework and the NCA’s DATF guidance. No monetary amount should be treated as a universal threshold below which reporting can be ignored.
Handle reports confidentially
The official SAR service is the destination for reports; this website does not accept case details or reporting submissions. Keep an appropriate internal record of the decision and any next steps.
Restrictions on tipping off and prejudicing investigations require care when communicating with clients, directors, buyers and creditors. A statutory conduct report, a police crime report or a report to OFSI may also be needed: one reporting route does not automatically discharge the others.
Scotland: source route
The AML framework is UK-wide and applies alongside Scottish insolvency law. Distinguish a Scottish company appointment from sequestration, a protected trust deed or DAS work. The scope of the regulated activity and the origin of contributions or third-party funding require their own assessment; the procedure’s title does not answer those questions.
Sources & review
Read the source in its own context. Legislation may contain commencement provisions and changes not yet applied to the displayed text. Professional guidance is identified separately from law.
Initial source-based editorial review: 26 Oct 2026. Next scheduled review: 26 Nov 2026. Substantive changes are reviewed before publication.
Added in the practice and regulation expansion requested on 26 October 2026. Primary-source editorial check; this is not independent professional approval. Future measures are distinguished from provisions in force.
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