ASK MAT – I SUBMITTED A SAR TO THE JFIU AND THEY OFFERED SOME FEEDBACK – IT WAS NOT GREAT, HELP

ASK MAT – I SUBMITTED A SAR TO THE JFIU AND THEY OFFERED SOME FEEDBACK – IT WAS NOT GREAT, HELP

MAY SAYS:

I'm sorry to hear about the feedback, but don't worry, I know how stressful it is to submit a SAR, especially when you don’t do many. 

Here is some background:-

• The Jersey Financial Intelligence Unit (FIU) evaluates the quality of Suspicious Activity Reports (SARs) based on several key criteria; however, it does not use a formal grading scale (such as A–F).
• Their feedback is designed to emphasise qualitative standards that help determine whether a SAR is practical and actionable.
• The FIU uses this feedback to help reporting entities improve their submissions and to ensure that SARs contribute effectively to Jersey’s AML/CFT efforts.
• That being said, I’m not aware that they have issued any specific guidance other than a POLSAR user guide.
• However, several Financial Intelligence Units (FIUs) and international bodies have issued guidance on how to submit high-quality Suspicious Activity Reports (SARs).
• These FIUs can give us some clues.

Here are some key sources of guidance:

United Kingdom (UKFIU / NCA) - The UK Financial Intelligence Unit (UKFIU) under the National Crime Agency (NCA) provides detailed guidance on submitting better quality SARs.

Key Points:

• Structure: Clearly outline the who, what, when, where, why, and how of the suspicious activity.
• Legal Basis: SARs must be submitted under the Proceeds of Crime Act 2002 (POCA) or Terrorism Act 2000 (TACT).
• Details Required:
• Reason for suspicion;
• Description and value of the property;
• Identities and roles of involved parties; and
• Any known links to criminal property.
• Glossary Codes: Use standard codes to help law enforcement categorise and prioritise reports.

📄 Full UK SAR Guidance (v9.0)[1] https://www.nationalcrimeagency.gov.uk/who-we-are/publications/650-guidance-on-submitting-better-quality-suspicious-activity-reports-sars-v9-0/file

United States (FinCEN) - The Financial Crimes Enforcement Network (FinCEN) provides a SAR Narrative Guidance Package to help institutions improve the quality of their SARs.

Key Points:

• Narrative Focus: The narrative is the most critical part—describe the suspicious activity in a logical, chronological order.
• Avoid Jargon: Use plain language and avoid acronyms unless well-known.
• Include:
• Who conducted the activity;
• What was unusual or suspicious;
• When and where it occurred;
• How it was detected; and
• Why is it suspicious.

📄 FinCEN SAR Narrative Guidance Package https://www.fincen.gov/resources/statutes-regulations/guidance/sar-narrative-guidance-package

European Union (EU FIUs / Europol) - The EU is working toward a unified AML/CFT framework, including enhanced cooperation between national FIUs.

Key Points:

• Directive 2015/849 and its updates require Member States to ensure effective SAR mechanisms.
• Europol’s “From Suspicion to Action” report emphasises:
• The importance of STRs (Suspicious Transaction Reports);
• The need for actionable intelligence; and
• The role of technology and cross-border cooperation.

📄 Europol Report – From Suspicion to Action https://www.europol.europa.eu/sites/default/files/documents/ql-01-17-932-en-c_pf_final.pdf

• SARs: The Key Quality Criteria

From the above, the Key Quality Criteria for SARs can be shown as follows:-

1. Clarity and Structure
• SARs should be logically structured and written.
• Avoid jargon or overly technical language unless necessary.
2. Detail and Specificity
• Include all relevant facts, dates, amounts, and parties involved.
• Vague or generic descriptions reduce the usefulness of the report.
3. Grounds for Suspicion
• Clearly explain why the activity is suspicious.
• The rationale should be based on observed behaviour, not just gut feeling.
4. Contextual Background
• Provide background on the customer or transaction to help the FIU understand the context.
• Include any relevant due diligence findings.
5. Timeliness
• Reports should be submitted promptly after suspicion arises.
• Delays can hinder investigations or allow criminal activity to continue.
6. Use of the SAR Template
• Proper use of the SAR template fields ensures consistency and completeness.
• The FIU is working on improving the PolSAR template to support better reporting. And it is rumoured that it will move to goAML, which many FIUs use as an integrated software solution worldwide.
7. Typology Awareness
• Reports that reflect awareness of known money laundering or terrorist financing typologies are especially valuable.

To assist you, I have created a SAR checklist based on these best practices. You can use this to draft or review SARs to ensure they meet the expected quality:

✅ SAR Quality Checklist – Jersey FIU Standards

1. Clarity & Structure

• [ ] Is the SAR logically structured and easy to follow?
• [ ] Are headings or sections used to organise the content?
• [ ] Is the language clear and free of unnecessary jargon?

2. Grounds for Suspicion

• [ ] Have you clearly explained why the activity is suspicious?
• [ ] Is the suspicion based on observed behaviour or facts (not just a hunch)?
• [ ] Have you referenced any red flags or typologies?

3. Detail & Specificity

• [ ] Are all relevant dates, amounts, and transaction details included?
• [ ] Have you named all individuals/entities involved?
• [ ] Are account numbers, addresses, and identifiers provided where applicable?

4. Contextual Background

• [ ] Have you included background on the customer or relationship?
• [ ] Is the customer’s expected behaviour or profile described?
• [ ] Have you explained how the activity deviates from the norm?

5. Timeliness

• [ ] Was the SAR submitted promptly after suspicion arose?
• [ ] Have you documented any delays and the reasons for them?

6. Use of SAR Template

• [ ] Are all mandatory fields in the SAR template completed?
• [ ] Have you used the correct format for dates, currency, and names?
• [ ] Is the narrative section comprehensive and well-written?

7. Typology Awareness

• [ ] Does the SAR reflect awareness of known ML/TF typologies?
• [ ] Have you linked the activity to any broader patterns or trends?

8. Supporting Documentation

• [ ] Have you referenced or attached relevant documents (e.g., transaction logs, KYC files)?
• [ ] Are these documents clearly labelled and easy to interpret?

 
References

Guidance on submitting better quality Suspicious Activity https://www.nationalcrimeagency.gov.uk/who-we-are/publications/650-guidance-on-submitting-better-quality-suspicious-activity-reports-sars-v9-0/file

SAR Narrative Guidance Package - FinCEN.gov https://www.fincen.gov/resources/statutes-regulations/guidance/sar-narrative-guidance-package

FROM SUSPICION TO ACTION - Europol https://www.europol.europa.eu/sites/default/files/documents/ql-01-17-932-en-c_pf_final.pdf

EUR-Lex - 52021PC0423 - EN - EUR-Lex https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52021PC0423