Government declines to reform the SARs regime in its response to the Law Commission report | Gary Pons writes for Lexis Nexis Corporate Crime analysis

Suspicious Activity Reports (SARs) require entities in the regulated sector, typically banks and financial institutions, to notify law enforcement where client activity might indicate money laundering or terrorist financing. An efficient and effective SARs regime will result in the provision of quality information to law enforcement, but in practice, too many SARs of poor quality are submitted.

This observation formed a central part of the Law Commission’s report on the SARs regime published in June 2019. It made recommendations designed to improve the quality of SARs by providing clear guidance to financial institutions. At the heart of its proposals were establishing an Advisory Board with oversight for the regime and issuing statutory...

This article examines:

  • The recommendations accepted by the government
  • The recommendations the government rejected
  • The ECCTA 2023 amendments
  • Conclusions

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Gary Pons is a talented and dedicated barrister. His approach to cases is distinguished by its careful preparation and measured execution. Gary is ranked in both Chambers and Partners (Band 1), and the Legal 500 for his work in the field of POCA and Asset Forfeiture work (all circuits). His experience in complex financial crime and asset forfeiture has allowed Gary to develop his practice over the years.

Gary has experience of foreign criminal proceedings having been involved for many years with two high profile cases in Costa Rica. He frequently advises on multi-jurisdictional asset recovery cases. His practice includes areas such as business crime, asset recovery and civil fraud, insolvency, and licensing.