On 7th November, Eversheds Sutherland published a briefing which looks at the report and considers the key statistics including a huge, but predictable, increase in Defence against money laundering (DAML) SAR and some surprising successes in terms of restrained funds.  There was another record increase in the number of SAR for the year.  The report discloses that the UKFIU made a decision on 69.81% of DAML requests without referral to law enforcement for a recommendation.

A DAML can be requested from the NCA where a reporter has a suspicion that property they intend to deal with is in some way criminal, and that by dealing with it they risk committing one of the principal money laundering offences under POCA 2002. A person does not commit one of those offences if they have received ‘appropriate consent’ (a DAML) from the NCA. These requests for a defence are the primary task of the UKFIU’s DAML Team. The report notes that the UK Government’s Economic Crime Plan flagging a commitment to protect the confidentiality of the SAR regime, in particular shielding SAR material from being disclosed in civil proceedings.  Credit and financial institutions continue to account for more than 95% of the SAR lodged, with accountants and tax advisors submitting 1% of the total SAR for the period, and independent legal professionals providing just 0.58%.


For more information on DAML, see –


This blog is primarily for my own use, to keep informed and up to date. However, if you would like to say thank you (and perhaps help me get a new, better laptop when I am away…) you can “buy me a coffee” at https://www.buymeacoffee.com/KoIvM842y

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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