The implementation of the Proceeds of Crime Act 2002 (POCA) has serious implications for financial institutions, who are committing an offence if they fail to report suspicion of money laundering. Consequently, banks have a responsibility to monitor their customers’ bank accounts and identify unusual transactions. By using computer algorithms, they are able to identify suspicious activity that could be connected with money laundering or terrorist financing.
Each bank will have a nominated officer who, under sections 330–332 of POCA, is under a duty to report suspicious information to the National Crime Agency (NCA). This is widely known as a Suspicious Activity Report (SAR). Whilst reporting the information to the NCA, the nominated officer will request consent from the NCA to proceed with the customer’s transaction.