Top Performing Posts - 3rd Place

Hi ,

Happy Monday.

This week I’m on holiday so I’ve lined up my top 3 performing LinkedIn posts from the last few months in case you may have missed any.

Enjoy and I’ll respond to mail when I’m back!

In third place my analysis of the UK FIU SARS Report:

UK FIU SAR Annual Report 2023/24

🇬🇧 United Kingdom | NCA

The NCA released the UK FIU SAR Annual Report 2023/24 last week. Below are my top three takeaways for MLROs - please feel free to chime in with objections/improvements.

1. New SAR Threshold = Criminals’ Invitation to “Micro-Launder”

• What’s happening: By raising the threshold under POCA from £250 to £1,000, the FIU cut out a chunk of lower-value SARs.

• Why it’s noteworthy: Can encourage criminals to exploit sub-£1,000 deposits or e-money flows for layering as they don’t trigger a DAML

• Takeaway for MLROs: Just because the law changed, your internal red flags should

The change in SAR threshold is brought up multiple times throughout the report and is probably the single biggest change from the previous year’s approach.

2. Extended Moratorium periods now the norm… with benefits

• What’s happening: Increased use of moratorium extensions on DAMLs. Investigations now stretch well beyond the 7-day notice period—leading to multi-week (even multi-month) limbos.

• Why it’s noteworthy: Banks are caught in the middle, dealing with frozen accounts, anxious clients, and repeated info requests.

• Takeaway for MLROs: You’ll likely face more iterative back-and-forth with the FIU and the customer. Prepare bulletproof audit trails

3. Terrorist Financing “One Big Hit” Trend: Fewer SARs, But Bigger Individual Values

• What’s happening: DATF (Terrorist Finance) SARs are still a fraction of total filings (406 DATFs out of 872k total), but single large-value refusals are cropping up—incl. a £1.7M refusal in 23/24

• Why it’s noteworthy: TF typically conjures images of small-scale fundraising. This larger SAR can imply more sophisticated/coordinated terror groups

• Takeaway for MLROs: Integrate TF indicators into your high-value alerts, not just lower-level

See you on Wednesday for the 2nd highest performing post…

Have a great Monday.

Paul