Reporting obligations
Under the relevant Irish or UK legislation, members and/or firms have Reporting Obligations. The legislation also sets out reporting obligations applicable to the professional body supervisors. If you are unsure of whether a report is required please refer to the guidance for the relevant jurisdiction.
Reporting Obligations - Republic of Ireland
In the Republic of Ireland, where obliged to report under the law, firms are required to submit the reports to the Garda Siochana and the Revenue Commissioners in accordance with the provisions of the Criminal Justice (Money Laundering & Terrorist Financing) Act 2010 as amended.
Update: Online Reporting of Suspicious Transactions
Chapter 7 of the AML Guidance discusses in detail the external reporting obligations for the MLRO within the accountancy firm. The Guidance is currently being updated to incorporate the latest changes to aml legislation in Ireland.
External STRs are now required to be made to both the FIU Ireland and the Revenue Commissioners via online systems. External STRs are submitted to the FIU Ireland using the GoAML Online System and to the Revenue Commissioners via the Reporting Online Service (ROS). Hard copy (paper) STRs are no longer accepted.
MLROs must be registered on both GoAML and ROS before submitting a STR. The MLRO is encouraged to register as soon as possible on both systems. In particular registration on GoAML will allow the MLRO access to the GoAML Message Board. This is a two –way secure communication. The MLRO will receive STR acknowledgements and alerts via the Message Board. Such alerts are not available to the public and will only remain on the Message Board for 6 months for security reasons.
Further information is available below.
ROS – Information on reporting to Revenue Commissioners is available at How to submit Suspicious Transaction Reports (STRS) (revenue.ie)
Reporting Obligations - UK
In the UK, firms must submit a Suspicious Activity Report (SAR) under either the Proceeds of Crime Act 2002 (POCA) or Terrorism Act 2000 (TACT) via SAR Online. Reporters should ensure that the defined criteria within the SAR is completed.
Guidance on reporting is included in the AML Guidance for the Accountancy Sector.
Submit reports (UK)
SAR - Electronic reporting
Please follow the below link to use the SAR Online service for reporting -
SAR Online
The National Crime Agency (NCA) takes the need to protect the confidentiality of reporters very seriously. For more information the ICAEW has issued Tech 07 06 the Confidentiality of SARs (see UK Law & Guidance page) regarding Money Laundering in the United Kingdom.
The United Kingdom Financial Intelligence Unit (UKFIU) has produced a document entitled Suspicious Activities Reports (SARs) - Top Ten Tips for the Accountancy Sector.
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