This flowchart, produced by Jon Gale, a Partner in the dispute resolution department at Ashurst LLP, is designed to help bank staff comply with their reporting obligations under the Proceeds of Crime Act 2002 (POCA).

It provides a short summary of the steps bank staff should take when determining whether a suspicious activity report (SAR) needs to be made to their money laundering reporting officer (MLRO) and on to the National Crime Agency (NCA) under POCA relating to suspected money laundering.

For a practical guide that explains the steps in more detail, see Practice note, Reporting obligations under the Proceeds of Crime Act 2002: guide for financial institutions.

Although the flowchart focuses on bank staff, the steps outlined are generally relevant for staff of other firms when complying with the POCA reporting obligations.