The Institute for Chartered Accountants in England & Wales has published information referring to a recent Home Office Circular on ‘Money laundering: the confidentiality and sensitivity of suspicious activity reports (SAR) in the context of disclosure in private civil litigation. It is recommended that the new guidance should be read in conjunction with a 2015 Circular which sets out the standard procedures followed by the police, other law enforcement agencies and the NCA in relation to the disclosure of SAR. It explained that the revised guidance sets out the steps that will help prevent SAR becoming disclosable in civil litigation cases. In particular, it helps to address the circumstances that arose from a civil case in 2019, where the court ordered that a SAR should be disclosed to the subject of that SAR as it was relevant to a breach of contract, breach of the Data Protection Act 1998 and defamation claim by a client.
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