The Law Commission : anti-money laundering and counter-terrorism financing - reform of the suspicious activity reporting regimes

In July 2018 the Law Commission published a Consultation Paper on proposed reforms to the United Kingdom (UK) suspicious activity reporting ( SARs) regimes relating to Anti-Money Laundering ( AML) and Counter-Terrorism Financing ( CTF). This article argues that, notwithstanding the proposed retention of an "all-crimes" approach to AML, the SARs regime may still be streamlined by way of the proposed amendments to the scope of reporting. The proposals to elevate the thresholds for reporting suspicions of money laundering, whilst conceptually appealing, present operational challenges for those within the reporting sectors