AFB Financial Crime Masterclass: Suspicious Activity Reporting in Practice: Detect, Decide, Disclose

A masterclass designed to guide and inform AML/CFT and financial crime professionals who are required to assess, investigate and make decision on whether to report Knowledge and Suspicious Activity Reports (SARs) to the local financial intelligence unit in full compliance with UK legal and regulatory expectations and according to the reporting guidelines of the NCA.

This is a highly interactive session, providing delegates with the opportunity to benchmark current policies, procedures and knowledge with peers to confirm good practice and identify opportunities to enhance performance.

Comprehensive guidance will be provided on the UK legal and regulatory framework, including the Proceeds of Crime Act 2002, the Money Laundering Regulations 2017 (as amended), and the Economic Crime and Corporate Transparency Act 2023. International global standards provided by FATF and local reporting procedures within the EU and US will also be covered to provide a comprehensive assessment of responsibilities.

The masterclass will focus on how to manage reports from the receipt of the initial report, determining whether a report meets the threshold of reportable subjective and objective suspicion, and how to complete a report to the NCA in full compliance with reporting requirements.

A key part of the technical guidance will be managing the risks of a customer relationship after a SAR has been submitted, including managing the process of ‘consent’, how to mitigate the risks of any civil liability under constructive trusteeship, and when and how to terminate a relationship.

COURSE CONTENT

During this masterclass, you can expect to learn more about:

• The importance of SARs, why they matter, and how they contribute to the management and mitigation of financial crime risks including money laundering, terrorism financing, and other predicate crimes by regulated firms
• Legal and Regulatory Frameworks for SAR Compliance: Gain clarity on the legal foundations underpinning SARs, including the UK Proceeds of Crime Act 2002, Terrorism Act 2000, Money Laundering Regulations 2017, and recent amendments under the Economic Crime (Transparency and Enforcement) Act 2023. Understand how these laws interact with the FATF’s 40 Recommendations, the global standard for suspicious activity reporting, and some defining requirements in the EU and USA
• Case law highlights and precedents that define the role of the Nominated Officer, and the definition of knowledge, suspicion and reasonable grounds for suspicion. This includes an examination of case law—including HSBC v Shah, R v Squirrel, R v Da Silva, and K v NatWest Bank
• Case law highlights and precedents that define the role of the Nominated Officer, and the definition of knowledge, suspicion and reasonable grounds for suspicion. This includes an examination of case law—including HSBC v Shah, R v Squirrel, R v Da Silva, and K v NatWest Bank
• Law enforcement insights – How SARs are used by law enforcement agencies. Analyse how SARs inform investigations, asset recovery, and enforcement operations—and understand how SARs are used to identify and restrain the proceeds of crime
• Managing SARs – The framework of SAR systems, controls, and processes. Learn more about the proportionate and effective SAR reporting framework that a firm is required to have in place including escalation processes, record keeping and managing information
• Conclude with an analysis of relevant enforcement action against firms to identify lessons learned

COURSE STRUCTURE

• In person instructor led
• 3 hours of learning
• Case study analysis
• CPD credits for any session attended
• Support with practical notes, working templates, and hands-on exercises

LEARNING OUTCOMES

By the end of this session, you will be able to:

• Explain the purpose and importance of Suspicious Activity Reports (SARs) in the detection and disruption of money laundering, terrorist financing, and other forms of financial crime, both in the UK and within the global compliance framework
• Assess the effectiveness of SAR activity and how to use data to inform the management of business and client financial crime risks
• Define personal and corporate responsibilities for reporting suspicion or knowledge of criminal property or activity, in line with the Proceeds of Crime Act 2002, the Terrorism Act 2000, and the Money Laundering Regulations 2017
• Describe the terms including unusual activity, objective and subjective suspicion, knowledge, and consent according to UK laws and regulations
• Demonstrate when and how to make a SAR, including what constitutes meaningful intelligence, how to complete a compliant report, and how to meet prescribed submission requirements to the UK National Crime Agency (NCA)
• Manage the operational and legal risks that arise post-reporting, including the risk of tipping off, prejudicing an investigation, and constructive trusteeship, as well as maintaining appropriate customer relationship management during periods of consent
• Evaluate and enhance SAR frameworks within the firm, using trend analysis, audit insights, and law enforcement feedback to strengthen internal systems and controls, while integrating SAR data into the wider financial crime risk assessment

WHO SHOULD ATTEND?

• Nominated Officers and Deputy Nominated Officers with direct responsibility for managing suspicion, receiving internal reports, and ensuring proper documentation and submission
• MLROs and Deputy MLROs responsible for firm-wide SAR processes, escalation procedures, and engagement with the UK National Crime Agency (NCA)
• Heads of Financial Crime Compliance (FCC) looking to enhance internal SAR governance, improve reporting quality, and align with UK, and EU regulatory standards
• Risk Managers, Investigators, and Internal Auditors assessing the design, execution, and effectiveness of SAR frameworks and post-reporting controls
• Aspiring AML Leaders preparing to step into roles involving SAR oversight, regulatory engagement, and broader financial crime responsibilities.

LOGISTICS & BOOKING INFORMATION

Venue:       Central London Venue TBC

Date:          Wednesday 15 July 2026

Time:         09:00 – 12:30 (Registration and light breakfast from 09:00)

Price:         £410 plus VAT

For further information please contact secretariat@foreignbanks.org.uk