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Guidance

The prevention of money laundering and combating the financing of terrorism

Guidance for remote and non-remote casinos: fifth edition

  1. Contents
  2. Part 8 - Suspicious activities and reporting
  3. 8 - Submission of suspicious activity reports

8 - Submission of suspicious activity reports

The NCA accepts the submission of SARs 152 in three main ways:

SAR Online

SAR Online is a secure web-based reporting system for small or medium sized reporting entities with access to the internet, which allows SARs to be submitted electronically through the NCA SAR Online System (link opens in a new tab). It is the NCA’s preferred method of reporting. Reporters must register themselves as a source (reporting entity) on the system once, and then submit SARs by completing linked electronic screens that reflect the fields included in the paper-based reports.

Requests for a defence (appropriate consent) can be submitted using SAR Online and, as long as the box for consent is checked at the start of the process, the system alerts the Consent Team automatically, ensuring swift identification and management of requests for a defence (appropriate consent). It is not necessary to send the request by fax as well as submission online.

SAR Online is the NCA’s preferred method for small and medium sized reporting entities to submit SARs. The benefit to the reporter is 24/7 reporting, an automatic acknowledgment of receipt with the ELMER reference number, and investigators are able to access the information more rapidly.

Paper-based reporting

Using the standard NCA Suspicious Activity Report Form. The NCA prefers submissions to be typed to enable them to be scanned and prevent errors in data entry. The form and guidance on using the form can be found on the NCA website (link opens in a new tab).

Completed forms should be posted to:

UKFIU
PO Box 8000
London
SE11 5EN

If using the form to request a defence (appropriate consent), it should be faxed immediately to 0207 238 8286, but it is not necessary to post and fax a request.

The paper-based reporting system will not elicit an acknowledgment of receipt or an ELMER reference number for your records, and the SAR will take some time to reach investigators.

Encrypted bulk data exchange

Encrypted bulk data exchange is used by high volume reporters, namely reporters with more than 10,000 reports a month. If an operator believes this would be the most appropriate method of reporting for their group, they should contact the UKFIU on 0207 238 8282 to discuss the matter.

Casino operators should include in each SAR as much relevant information about the customer, transaction or activity that it has in its records. The NCA has published a glossary of terms which they prefer operators to use when completing SARs. 153 This will assist in consideration of the report by the NCA.

Casino operators should ensure that they check all the facts they have about the customer and include all relevant information when submitting a SAR

This may include the following:

  • Do the staff know the customer’s identity?
  • Is a physical description of the customer available?
  • Has the customer provided any records that will assist in identifying him, for example credit or debit card details?
  • Has the customer ever self-excluded?
  • What are the customer’s product preferences, and does he hold other gambling accounts (for example, prefers casino gaming, but also uses online gambling facilities)?

In order that an informed overview of the situation may be maintained, all contact between the casino operator and law enforcement agencies should be controlled through, or reported back to, the nominated officer or a deputy acting in the absence of the nominated officer. The NCA may apply to the magistrates’ court (or, in Scotland, the sheriff) for an order (a further information order), following the submission of a SAR, requiring the nominated officer to provide more information in respect of the SAR. 154 Law enforcement agencies may also apply for a disclosure order requiring any person considered to have information relevant to an investigation to answer questions, provide information or to produce documents. 155

POCA also makes provision for the voluntary sharing of information between persons in the regulated sector when deciding whether to submit a SAR, and joint SARs by persons in the regulated sector, subject to certain limitations. The exchange of information in these circumstances is protected from breaching any confidentiality obligations or other restrictions. 156

References

152 Remote casino operators, particularly those based in a foreign jurisdiction, should consult the Commission's advice note on Anti-money laundering: Suspicious activity reporting requirements for remote operators (PDF). It is intended to assist remote operators in determining to which body or Financial Intelligence Unit (FIU) known or suspected money laundering activity should be reported, and the circumstances in which a defence (appropriate consent) should be sought.
153 NCA - Suspicious Activity Reports (link opens in a new tab)
154 Section 339ZH (link opens in a new tab) of POCA.
155 Section 357 (link opens in a new tab) of POCA.
156 Sections 339ZB (link opens in a new tab) to 339ZG (link opens in a new tab) of POCA.

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External reporting
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Requesting a defence
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