On 8th July, Dentons published a briefing on the results of consultation launched in 2018 on the reform of the suspicious activity report (SAR) regime created by Part 7 of the Proceeds of Crime Act 2002 (POCA), the so-called “SARs regime”.  Dentons says that, despite the apparent need for comprehensive reform, the Law Commission’s recommendations are limited in nature with an emphasis on further guidance rather than a root and branch overhaul of the SAR regime.  The article notes the emphasis on additional guidance, and the few proposed changes to the regime.  Dentons concludes that those in the regulated sector might be forgiven for thinking that most of the key issues have not been dealt with and little has been done to address the real concerns expressed about the operation of the regime.


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Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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