Civil: 004/2021: money laundering: the confidentiality and sensitivity of suspicious activity reports (SARs) in the context of disclosure in private civil litigation

19 Jul 2021 9:40 AM | Anonymous member (Administrator)


1. This Circular sets out the position that Her Majesty’s Government takes regarding the use of Suspicious Activity Reports (SARs) in private civil litigation matters. It should be read in conjunction with Home Office Circular 022/2015. The purpose of this Circular is to provide guidance to help protect reporters of SARs (including but not limited to financial institutions and professional services firms), the subjects of SARs and the integrity of the SARs regime wherever possible. Reporters should consider how they can apply points set out in the circular to contribute towards maintaining the wider effectiveness of the SARs regime. For the avoidance of doubt, this circular does not affect any legal obligations of disclosure including under the Civil Procedure Rules 1998 or under an order of the court.

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