Reporting suspicious activity

When something doesn’t feel right – Take Action 

If something doesn’t feel right about a client or transaction, it’s important to act. Your response will depend on the nature and severity of the concern.

Immediate risk or criminal activity

• If there is an immediate risk to life or safety, call 999.
• To report fraud or cybercrime, contact Action Fraud at 0300 123 2040 or visit actionfraud.police.uk.

Suspicious Activity Indicators

Common red flags include:

• Clients who are evasive, contradictory, or unusually secretive
• Transactions that are unusual in size, nature, or frequency for the client’s profile
• Requests that don’t make commercial sense or lack a clear purpose.

For further context and legal basis, see the NCA SARs guidance.

Submitting a Suspicious Activity Report (SAR) 

If you have knowledge or suspicion of money laundering or terrorist financing, you must submit a SAR to the National Crime Agency (NCA). The threshold for suspicion is low; if there’s a possibility that’s more than fanciful, a SAR should be submitted.

• Register and submit via the SAR Online Portal
• Include all relevant details, including:
  • Names, dates of birth, addresses
  • Transaction details and suspected criminal property
  • A clear and concise reason for suspicion
• If reporting a crime alongside a SAR, include the crime reference number and organisation details in the SAR narrative.

Refer to the UKFIU’s SARs Reporter Booklet (July 2025) for case studies and best practice, and follow the UKFIU guidance on submitting better quality SARs.

Important reminders 

• If the funds involved are not yet the proceeds of crime, it may be attempted fraud, not money laundering.
• The SAR system is not a substitute for crime reporting. You may still need to report the matter via other law enforcement channels to ensure the right agency receives the information.

Internal concerns and Whistleblowing 

If you have concerns about AML compliance within your firm, you can make a confidential report under our Whistleblowing Policy.

This does not replace your legal duty to file a SAR where required.

People with Significant Control (PSC) Discrepancy Reporting Obligations 

Under the UK’s anti-money laundering regulations, firms are required to verify the beneficial ownership of prospective clients before establishing a business relationship. This includes obtaining an extract from the client’s PSC register and checking it against the information gathered during customer due diligence.

If a material discrepancy is identified, meaning the information held by the firm differs significantly from what is recorded at Companies House, and that discrepancy could reasonably be linked to:

• Money laundering
• Terrorist financing
• Concealment of business details

then the firm must report it to Companies House.

Reporting requirements 

• Reports should be made as soon as practicable, and normally within 15 working days of discovering the discrepancy.
• Use the Companies House discrepancy reporting form.
• This obligation applies to obliged entities, including legal professionals, under the Money Laundering Regulations 2017.

Important distinction 

A PSC discrepancy report is not a substitute for a Suspicious Activity Report (SAR). If you know or suspect that the discrepancy is part of a broader criminal activity, such as money laundering or terrorist financing, you must also submit a SAR to the National Crime Agency (NCA).

Additional Guidance

• Companies House has published a Summary Guide for Companies to help organisations understand their obligations around PSC registration and updates.
• Firms should incorporate PSC checks into their Practice-Wide Risk Assessments (PWRAs) and ensure staff are trained to identify and report discrepancies.

Requirement to register an overseas Entity –  transparency in UK property ownership 

The Register of Overseas Entities (ROE) came into force on 1 August 2022 under the Economic Crime (Transparency and Enforcement) Act 2022. It forms part of the UK’s strategy to improve transparency in property ownership and combat economic crime.

Any overseas entity that wants to buy, sell, transfer, lease, or charge property or land in the UK must register with Companies House and disclose details of its registrable beneficial owners or managing officers.

How to Register

Companies House provides detailed guidance on:

• How to register an overseas entity
• What information must be disclosed about beneficial owners and managing officers
• The verification process, which must be completed by a UK-regulated agent.

You can access the Register of Overseas Entities guidance and start page here. 

Annual update statements – new requirements from 31 July 2025 

From 31 July 2025, overseas entities must include in their annual update statements any changes to beneficial ownership that occurred during the pre-registration period (28 February 2022 to 31 January 2023). This information must be:

• Verified by a UK-regulated verification agent
• Submitted even if the entity registered before 31 January 2023
• Included in the next update statement due after 31 July 2025.

Failure to file an update statement on time is a criminal offence and may result in prosecution or fines. It will also invalidate the entity’s Overseas Entity ID, preventing property transactions in the UK.

Access to Trust Information – effective 31 August 2025 

From 31 August 2025, the public may apply to Companies House for access to trust information held on the ROE. This includes details of:

• Trust beneficiaries
• Settlors and grantors
• Protectors and other interested parties

A widened protection regime is also in place, allowing individuals at risk of harm or intimidation to apply to have their information withheld from public disclosure.

Enhanced protection for at-risk individuals 

Individuals whose information appears on the ROE, including minors and vulnerable persons, can now apply for protection if disclosure could put them or someone they live with at serious risk. Protected information includes:

• Name and former names
• Date of birth and nationality
• Residential and service addresses
• Email address.

For full guidance, visit the Register of Overseas Entities page on GOV.UK