Suspicious Activity Reporting (SAR)

Policy & Template for identifying, reporting, and managing suspicious activities

Effective 17 Jun 2025
Contents
1. Purpose

This policy explains:

  1. When Unicorn Currencies staff must file a Suspicious Activity Report (SAR).
  2. The internal procedure and timelines.
  3. The information required for the SAR template.

It complies with the UK Proceeds of Crime Act 2002 (POCA), Terrorism Act 2000, Money Laundering Regulations 2017 and FINTRAC obligations in Canada.

2. Who Must Report?

Internal Staff

All employees, contractors and temporary staff.

External Partners

Partnered service-provider staff handling Unicorn Currencies transactions.

3. Triggers for a SAR

File a SAR if you know or suspect that a transaction relates to:

ML-01

Money Laundering

Rapid layering between multiple currencies without commercial rationale.

TF-02

Terrorist Financing

Payments to high-risk jurisdictions with no clear business link.

FRA-03

Fraud or Scam

Customer account receiving multiple charge-backs or APP fraud funds.

SAN-04

Sanctions Evasion

Attempt to deal with a name matching OFSI / OFAC list.

"Suspicion" = more than speculative, less than proof.

4. Internal Escalation Workflow
1

Immediate Alert

Alert Money Laundering Reporting Officer (MLRO) via SAR Portal orsar@unicorncurrencies.com

2

Await MLRO Approval

Before processing / freezing the transaction (defence against money-laundering).

3

MLRO Review

MLRO reviews within 1 Business Day; may request extra info (invoices, KYC, communications).

4

MLRO Decision

MLRO decides to (a) file SAR to NCA (UK) / FINTRAC (CA) or (b) document rationale for no-SAR.

Important Warning

Do not inform the customer ("tipping off" offence).

5. Timelines
StepUK (NCA)Canada (FINTRAC)
Internal escalation to MLROAs soon as practicable (same day)Same day
Filing SAR after decision"Without delay" – within 24 h"Immediately" – within 24 h
6. Record-Keeping

Retention Period

All SARs and related documents retained minimum 5 years.

Access Control

Access restricted to MLRO, Deputy MLRO and Compliance Officers.

7. Training & Awareness

Mandatory AML e-learning

(annual)

Quarterly refresher emails

on red-flag typologies

SAR drill

during new-hire induction

8. SAR Template (Internal Use)

Suspicious Activity Report (SAR) Form

Ref: SAR-[[auto-ID]]
Date/Time raised: ____
Raised by (name/role): ____
Customer ID / Account No.: ____
Transaction ID(s): ____
Amount & Currency: ____
Date of transaction: ____
Full description of suspicion (who, what, where, when, why): ____
Source of funds (if known): ____
Supporting evidence attached? (Y/N): ____
Recommended action (freeze / continue / other): ____
MLRO decision: ____
Date filed to NCA/FINTRAC (if applicable): ____
SAR reference No. (NCA or FINTRAC): ____
Follow-up / account monitoring notes: ____
9. Contact

Money Laundering Reporting Officer (MLRO)

sar@unicorncurrencies.com
+44 020 8064 0818 (option 4)
© 2025 Unicorn Currencies Ltd & Unicorn Currencies Limited – All rights reserved.