Sometimes, we read numbers but the actual scale of them evades us. It doesn’t feel like too long of a wait before the NCA receives a million SARs in a year— that’s one SAR for every seventieth person in the country, which seems like a lot. Research on the topic shows that some firms over-report to ensure compliance, while in ‘newly regulated’ spaces, SAR numbers are much lower and might rise over a period of years as industries ‘settle into’ obligations.

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SAR writers don’t often get to see the full journey of their SAR. This month, the NCA has released its latest SARs Reporter Booklet detailing feedback from law enforcement agencies on their use of SARs. The booklet offers interesting insights into how one SAR can make all the difference, whether by drawing attention to an otherwise hard-to-piece-together network of criminality backed by public crime reports, or by showing how law enforcement agencies can offset money mules if they have the right information.

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Whether you think that we’re submitting too many (or too few) SARs, there’s no denying that writing a SAR is a skill. When you look at the bestseller shelves in airport bookshops (the worst of bookshops, but beggars can’t be choosers), many of the novels are about financial crimes.

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SAR writing is all about telling a good story...

So here’s a reminder on the main tips and tricks.

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1. Don’t forget the main details Your character is more than a name. You know their occupation and where they reside. You know when they opened their product— and you know how they use it. For the sake of our SAR, they might be main character, or they might be an associated one.‍
2. Use a glossary code Books are sold in genres (like crime, or romance). It’s not mandatory to use a glossary code, but if you think of it like a genre, you have a better chance of your SAR getting to where it needs to, as quickly as it needs to it, if you use one. ‍
3. A story needs a start, a middle and a finish Think back to lessons about writing essays in school. Start your SAR by setting the scene with basic information. Detail the transactions that have led you to suspect criminality. Finish by breaking it down into chunks that justify your case.‍
4. Provide context Some books are simply unintelligible. That seem to be fine if you want to win prizes, but your SAR isn’t going to win the Booker (sorry), so clarity is key. There’s not much point in telling the NCA that you think money laundering has occurred if you don’t explain how you came to that conclusion. Don’t leave chapters out.‍
5. Don’t James Joyce it Keep your thoughts coherent and your words simple and unambiguous. The clearer you can be, the more useful your SAR will be to a law enforcement agent trying to get a grasp of the situation solely through your eyes. Joyce wouldn’t have been good at SARs.

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Just a few days ago, the FCA released its findings on Firms’ use of the National Fraud Database (NFD) and money mule account detection tools. While the regulator was reassured that firms reported money mules in SARs to the NCA, they noted that there were instances were SARs should have been raised and weren’t. In November 2023, the regulator had raised a similar issue in its findings on Proceeds of fraud— Detecting and preventing money mules, noting that SARs sometimes weren’t raised promptly enough, which the regulator said was “extremely important in tackling the mule network.”

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Writing good SARs is time consuming, and often you won’t have hours to structure an essay. SARs have to be filed in a timely manner, and backlogs of SARs can build up fast. If you want top quality SAR writing at high volume, DCM can support by providing you with knowledgeable experts who can write comprehensive SARs and still meet tight deadlines. Reach out by emailing us at info@dcmoperations.com and let us know how we can help your business.

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The NCA Reporters Booklets from across the years give plenty of examples of well executed SARs that led to useful outcomes and that should be the goal of every single one of the country’s million SARs. If we can make our SARs clear, strong and robust, we’re taking one more step toward reducing crime and protecting our own friends and families.