UK SAR decision tree

Crime is an action or inaction prohibited by law and punishable by the state, and it is not civil wrongdoing for which restitution is owed to another person.

Where a representative of the state (such as HMRC) can decide whether to treat conduct as a criminal or a civil matter, for the MLTF regime, businesses should consider the conduct as criminal, even where the state's decision is frequently or even invariably, to treat it as civil.

SOURCE

https://www.ccab.org.uk/wp-content/uploads/2022/05/SupplementaryGuidanceTaxPractitioners_2019Version-2.pdf