What should accountancy firms include in a SAR?
Last updated: July 24, 2026
When an accountancy practice submits an external suspicious activity report (SAR), it must turn information from the client engagement into financial intelligence that law enforcement can understand and use.
The narrative needs to identify the relevant people, activity, and suspected criminal property, then clearly show how the available evidence led to suspicion.
The reporting duty is not satisfied by sending an unexplained concern. The SAR must provide the UK Financial Intelligence Unit (UKFIU) with sufficient specific information to understand the report and assess its intelligence value.
Key takeaways
- Reliable identifying information is needed for every material person or entity named in the SAR.
- The SAR should focus on transactions and events that explain the suspected activity, rather than including unnecessary engagement history.
- Suspected criminal property should be identified clearly, including any known value, location, or control details.
- The reason for suspicion should connect the observed facts with the client’s expected activity
- The SAR must separate confirmed information from assumptions, external intelligence, and unresolved points.
- Before submission, the SAR Portal fields and narrative should be relevant and clear.
Why SAR content must be clear and specific
A SAR is financial intelligence submitted to the UKFIU under the statutory reporting framework in the Proceeds of Crime Act 2002 (POCA).
While SARs do not need to prove an offence or read like an audit report, they must give the UKFIU enough specific information to understand the suspected money laundering activity and assess the disclosure.
Sections 330 and 331 of POCA set the failure-to-disclose duties for the regulated sector and nominated officers.
The relevant point for accountancy firms is that the SAR should identify the subject and suspected property. It then needs to set out the facts that gave rise to suspicion without relying on the client file.
Even so, the underlying client file should still support the firm’s reasoning if an AML reviewer later checks how the concern was identified and handled.
Accurate identifiers also help the UKFIU match the SAR with existing or later intelligence, so the report can support immediate enquiries or retain value over time.
In its thematic review, ICAEW draws attention to low-utility SARs that lacked actionable detail or a clear account of the suspected activity and related proceeds. Therefore, the SAR should give the UKFIU a focused disclosure that can be acted on, instead of a general record of unease or internal concern.
HMRC sector risk guidance can also help explain why particular activity looked unusual in the context of the firm’s client base or services.
Identifying the parties in a SAR
A SAR should identify the main subject using information already held through customer due diligence and routine engagement work.
Individuals can be described through the available core details, while entities require corporate information and any supporting detail needed for reliable identification.
The report then connects any associated person or entity to the subject and suspected activity, with their role explained where known. Victims and uninvolved counterparties are described by reference to their actual role, so the report does not imply participation.
Once those roles are clear, the engagement context can show why the information mattered to the suspicion, rather than leaving the UKFIU to infer its significance from the client relationship.
Relevant activity and suspected criminal property
The relevant activity needs to be set out in traceable terms, using precise dates and transaction details that explain the concern. Including every transaction is rarely helpful, as routine entries can obscure the pattern behind the suspected activity.
The SAR should then state the criminal or terrorist property in question, including its value and current location. It also needs to identify who controls those assets and why they could amount to a benefit from criminal conduct.
Note that criminal property can also include a financial benefit, such as value retained or liability avoided.
For cross-border activity, the report must identify the jurisdictions and explain the UK connection. When information is incomplete, the narrative should state what is unknown.
Importantly, a known gap in the information is different from a matter the firm has checked and disproved.
Reasoning that links the facts to suspicion
Labels such as “suspicious transaction” or “no commercial rationale” do not explain the AML concern.
The firm’s observations and their significance in the client’s circumstances should therefore be clearly explained.
If activity departed from expectations, the SAR needs to first describe the position supported by the client’s account and available engagement evidence. The difference between that position and what occurred then explains why the concern arose.
That said, a short reasoning chain often gives the clearest explanation.
For example, records might classify a payment as a supplier expense while the client says it relates to stock. If invoices and inventory records show no matching purchase, the firm might suspect that the payment and related tax deduction represent a criminal benefit.
The same discipline applies to uncertainty. Verified facts need to be kept separate from unverified or evaluative material, and any remaining uncertainty must be labelled.
A suspected underlying offence should be named only when the facts provide a reasonable basis. When external information has contributed to the concern, the SAR must still explain the firm’s own suspicion.
Furthermore, if a published source contributed significantly, the relevant finding should be summarised and accompanied by a dated citation instead of a bare link.
Practical takeaway: SARs should rely on information obtained during the engagement and through reasonable internal enquiries. Extending the work solely to strengthen the report can create avoidable risk, including alerting the client.
Clear, chronological, and self-contained SAR narratives
The narrative should open with one or two sentences that identify the subject and summarise the suspicion. It then needs to state the firm’s relationship with the subject and present the material events in date order, followed by the reasoning and any intended action that may assist law enforcement.
The narrative is clearer when it uses short paragraphs and plain professional English. Technical terms need a brief explanation if their significance would not be obvious outside the accounting profession.
The UKFIU should also understand why the professional or commercial detail matters without consulting the underlying engagement records.
Exact amounts are stronger than vague descriptions of scale, because the reason-for-suspicion field is limited to 8,000 characters; repetition and engagement history that does not help explain the suspicion should be removed without losing essential facts.
Relevance and consistency before the SAR submission
Every material party should be identifiable and clearly connected to the activity, with consistent supporting transaction information across the structured fields and narrative.
The report must state both the suspected property and the reason for suspicion, and any qualification or uncertainty in the information should be presented explicitly.
Previous SAR reference numbers must be included where applicable, while selection of Portal glossary codes should be limited to codes supported by the facts. Moreover, the SAR narrative should explain why each code applies.
The report should exclude irrelevant or unsupported material, including internal identifying information.
In summary
A compliant SAR enables a UKFIU officer with no prior knowledge of the engagement to follow the facts and understand why they caused concern.
To achieve that, the report should focus on the evidence that matters and present events in a logical order. The reasoning should then be explained in straightforward language, using information already available to the practice.
Uncertainty should be identified honestly, while unnecessary detail needs to be left out. This enables a concise disclosure that gives the UKFIU the subject, suspected property, and basis for suspicion without turning the SAR into a full client-file history.
FAQs
There is no ideal word count, yet strong narratives contain enough detail to identify the subject, explain the relevant activity, and show why the circumstances raised concern. With only 8,000 characters available, background information and routine transactions that do not help the UKFIU understand the matter being reported are unlikely to be needed.
The client information included should be limited to what is needed to explain the concern. Relevant context can include the firm’s engagement and the client’s normal business activity. Wider background about the work undertaken is unlikely to help unless it explains why a particular transaction or payment appeared unusual for that client.
The report should use the precise information available to the firm and state clearly what remains unknown. Estimates, assumptions, or unconfirmed explanations should not be presented as fact. For example, if the destination of funds cannot be established, that point should be stated directly. This helps the UKFIU tell missing information apart from issues that the firm has examined and resolved.
The person or organisation should be described according to their actual connection with the activity. The narrative needs to indicate whether they appear to be a victim, customer, supplier , or other counterparty. The wording should not suggest that they share the subject’s suspected involvement. Their identity, role, and relationship must be clear from the details provided.
Public information can be included if it helped prompt or inform the firm’s concern. The relevant finding should be recorded together with the publication and date. The observations arising from the firm’s work and their bearing on the suspicion should remain explicit. A source reference without explanation can leave the UKFIU without the context needed to understand its relevance.
The factual basis should come from material gathered through the engagement and any reasonable checks made internally. Contacting the client solely to complete the SAR could make them aware of the concern. If further information is unavailable, the report should state the missing point directly and avoid speculation.
References and Source Material
- HMRC, Economic Crime Supervision Handbook (ECSH34225 – Suspicious activity reports)
- CCAB, Anti-Money Laundering and Counter-Terrorist Financing Guidance for the Accountancy Sector
- HMRC, Risks common to accountancy service providers
- Money Laundering Regulations 2017
- Proceeds of Crime Act 2002, Part 7
- HMRC, Accountancy sector guidance for money laundering supervision
- National Crime Agency, Suspicious Activity Reports
- National Crime Agency/UKFIU, SARs Reporter Booklet January 2025
