Section 330 POCA: failure to report is a criminal offence. Section 333A: tipping off is a criminal offence. Navigate both.
The Proceeds of Crime Act 2002 creates a criminal offence (s.330) for failing to report knowledge or suspicion of money laundering. The Tipping Off offence (s.333A) creates a criminal offence for disclosing the existence of a SAR. For the MLRO in a small firm — often the same person as the COLP — navigating these competing obligations while running a practice is genuinely difficult. When should you file? How do you handle the consent regime? What happens during the 7-day notice period and 31-day moratorium? How do you manage the file without tipping off the client? Your agent helps the MLRO through the process: assessing red flags, drafting the SAR in the correct NCA format, tracking consent periods, and maintaining the suspicious activity log — all while ensuring the firm meets its obligations without inadvertently tipping off.
What Your Agent Actually Does
Your agent helps your MLRO navigate SAR obligations — assessing red flags, drafting reports, tracking consent periods, and maintaining the suspicious activity log.
Identifies red flags from matter data
Unusual transaction patterns, funds from unexpected sources, client behaviour inconsistencies, rushed completions with pressure to move funds quickly — your agent monitors matter data for red flags that should trigger MLRO consideration. Not automated reporting — flagging for human assessment.
Drafts SARs in NCA-required format
When the MLRO decides to report, the SAR must be submitted to the NCA in the correct format with sufficient detail. Your agent drafts the SAR from the matter data, ensuring all required fields are completed and the narrative is clear and factual.
Tracks consent requests and moratorium periods
Consent SARs trigger a 7-day notice period, then a potential 31-day moratorium. Your agent tracks these periods, alerts the MLRO when consent is granted or refused, and manages the timeline so the firm doesn't inadvertently proceed during the moratorium.
Maintains the firm's suspicious activity log
Every internal report to the MLRO — whether it results in a SAR or not — should be logged with the date, source, circumstances, MLRO assessment, and outcome. Your agent maintains this log, creating the evidence that your firm's internal reporting system functions properly.
Provides tipping-off safeguards
Managing a file during a SAR investigation without alerting the client requires careful communication. Your agent flags communications that could constitute tipping off and suggests alternative approaches — helping fee earners navigate the most legally perilous part of AML compliance.
The real numbers.
| MLRO/COLP time on SAR management | £1,000–£3,000/year |
| External legal advice on SAR decisions | £500–£2,000/year |
| Criminal liability risk for failure to report | Severe (criminal offence — up to 5 years imprisonment) |
| Realistic annual cost | £2,000–£6,000 |
| Agent build (one-off, configured to your MLRO workflow) | £2,000–£3,500 |
| Monthly running costs (hosting + AI usage) | £60–£120/month |
| NCA and POCA regulatory updates | Included in first year |
| Realistic first-year total | £2,720–£4,940 |
SAR management is where AML compliance becomes genuinely high-stakes — criminal liability for both failure to report and tipping off. For MLROs in small firms who are also fee-earning partners, managing these competing obligations alongside their normal caseload is one of the most stressful aspects of practice.
Your agent doesn't make the reporting decision — that's always the MLRO's professional judgement. It ensures the process is followed correctly, the paperwork is right, and the timeline is tracked.
Good fit / not a fit.
This works brilliantly for:
- Firms where the MLRO is also a fee-earning partner (most small firms)
- Conveyancing practices handling high-value property transactions
- Firms that have filed SARs and found the process administratively burdensome
- COLPs who want a documented internal reporting process for SRA inspection
This probably isn't for you if:
- Your firm is outside the scope of MLR 2017
- You have a dedicated MLRO who manages SARs full-time
- You have retained external counsel advising on all SAR decisions
Let's talk.
We'll start with your current SAR process, how many internal reports your MLRO handles per year, and whether you've found the consent regime timeline management challenging. Usually a 15-minute conversation.
hello@nimblecroft.com