National Crime Agency updated guidance on Suspicious Activity Reports (SARs)

In November 2025, the National Crime Agency (NCA) issued updated guidance on Suspicious Activity Reports (SARs), which replaces all previous guidance.

The NCA remains clear that SARs are a key intelligence tool in the fight against money laundering, terrorist financing and wider financial crime.

This position is strongly reinforced by the Solicitors Regulation Authority (SRA) in its latest annual report, which highlights both the continuing risks faced by the legal sector and the importance of submitting high-quality, well-reasoned SARs that genuinely assist law enforcement.

For professional service providers, including solicitors, the updated guidance introduces important clarifications that firms need to understand and embed into their AML frameworks.

Key changes in the NCAs 2025 SAR guidance

1. A greater emphasis on quality over quantity

    

   The NCA is now explicit that submitting a “good-quality SAR” is essential. This message has also been strongly echoed by the SRA in its most recent annual report, following its review of SARs submitted both by firms and by the regulator itself.

   A good-quality SAR should include sufficient detail and context to allow the various investigating agencies to understand:

   • what the suspected criminal activity is,
   • why it is suspicious
   • what services the firm is providing, and
   • what the future intention is for the client relationship.

   
   Minimal or poorly detailed SARs are unlikely to be effective.

   The SRA’s own reporting activity illustrates this point. During the 2024/25 reporting period, the SRA submitted 19 SARs to the NCA (down slightly from 23 in 2023/24), but these SARs related to more than £148 million in suspected criminal proceeds, almost double the value reported the previous year. This reinforces the regulatory focus on quality rather than volume.

2. SAR Portal guidance

    

   All SARs should now be submitted via the official SAR Portal, with the updated guidance providing clear instructions on how to do so.

   The move to digital reporting is intended to:

   • improve consistency and completeness
   • support faster intelligence analysis, and
   • reduce delays, particularly where consent is required.

   
   The SRA has noted that poor-quality SARs can cause unnecessary delays, especially where a Defence Against Money Laundering (DAML) is submitted. These delays can be difficult for firms to manage and explain to clients, reinforcing the importance of getting SARs right first time round.

3. Defence Against Money Laundering (DAML) / Defence Against Terrorist Financing (DATF)

   
   The updated guidance provides greater clarity around how professionals can seek legal protection when submitting SARs.

   Where a solicitor suspects that property they intend to deal with may represent the proceeds of crime, proceeding without consent could result in committing a principal money laundering offence. Submitting a DAML SAR and receiving appropriate consent from the NCA provides a statutory defence under Proceeds of Crime Act 2002 (POCA) and Terrorism Act 2000 (TACT).

   The SRA’s inspection work shows that firms are generally engaging with this process appropriately, but it continues to stress that DAML SARs must be clearly drafted and fully reasoned to avoid delays and regulatory exposure.

Why this matters for legal firms

Solicitors are frequently involved in transactions where suspicious activity may arise. While legal professional privilege will apply in certain circumstances, there are many situations where submitting a SAR is both lawful and mandatory to comply with AML obligations.

The SRA’s annual report highlights that SARs submitted by the regulator itself often stem from:

• inadequate client due diligence or source of funds checks
• high-risk or opaque funding structures, and
• transactions that fall outside a firm’s usual business profile.

Property work remains the single highest risk area, with the SRA confirming that 73% of all SARs it submitted involved property conveyancing, across both residential and commercial matters.

Examples where solicitors should consider filing a SAR

• Unusual property transactions
  For example, a client seeking to purchase high-value property using funds from multiple or unknown sources, raising concerns about proceeds of crime.
  
  
• Suspicious client funds
  Instructions to transfer funds to or from higher-risk jurisdictions, including those involving Politically Exposed Persons (PEPs), without a clear legitimate purpose.
  
  
• Unexplained wealth
  Clients receiving large sums through complex or opaque structures with no apparent lawful explanation.
  
  
• High-risk corporate clients
  Acting for clients operating in sectors with elevated AML risk (such as gaming, crypto or high-value goods), where the source of funds is inconsistent with the client’s business profile.
  
  

The SRA has also highlighted risks arising from:

• fraud-related funds (including vendor fraud)
• use of office accounts to move suspicious money
• transactions with no underlying legal work, and
• firms inadvertently facilitating activity outside the scope of the MLR 2017.

In all cases, firms should carefully document their decision-making and ensure SARs are sufficiently detailed.

Practical steps to ensure compliance with the NCAs guidance around Suspicious Activity Reports

1. Review internal policies – ensure your firm’s AML procedures reference the November 2025 guidance and the SAR Reporter Booklet and where to find these. The latest copy can be found here.
   
   
2. Use the SAR Portal – register and familiarise yourself with the portal to ensure accurate and timely submissions.
   
   
3. Provide clear, detailed SARs – Include all relevant information: context, client details, transaction history, and why the activity appears suspicious.
   
   
4. Understand DAML/DATF – where legal privilege or confidentiality may be an issue, ensure you follow the procedures to obtain protection.
   
   
5. Train your team – The SRA continues to stress the importance of training staff involved in onboarding and transaction handling, particularly in high-risk areas such as conveyancing.

In summary…

The November 2025 SAR guidance reflects the NCA’s focus on quality, clarity, and compliance. For solicitors and other professional service providers, the changes offer both practical guidance and reassurance, allowing you to report suspicious activity confidently while managing risk.

Ensuring your firm is up-to-date is not just good practice – it’s essential to staying compliant in an increasingly complex regulatory environment.