New Suspicious Activity Reports (SARs) Portal
The National Crime Agency has announced the new SAR portal will go live on 18 September 2023. Two user guides, two video guides and a FAQs document have been developed.
Business Owners Officers and Managers (BOOMs)
In the excitement of announcing newly promoted and lateral hire partners, recent requests for advice suggest that it is easy to forget that firms which are in the regulated sector for anti-money laundering purposes must obtain prior authorisation from the SRA; failure to do so is a criminal offence. Note that the definition of ‘Managers’ under The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 is not the same as under the SRA Standards and Regulations and will often include roles sitting below the Officers, including senior leadership team, heads of departments or practice areas.
SRA updates
Since our July Risk Update, the SRA has updated its Sectoral Risk Assessment to include reference to proliferation financing, and its AML Questions and Answers to include a further question on sanctions checking on counterparties.
See www.legalrisk.co.uk/News for links to documents referred to above.
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