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Making a Suspicious Activity Report (SAR)

Knowing when and how to make a Suspicious Activity Report is one of the most sensitive parts of Anti-Money Laundering compliance for law firms. This course gives fee earners, supervisors and MLROs a clear, practical framework for handling suspicion—recognising when the reporting threshold is met, escalating internally, and engaging with authorities without tipping off clients.

Online, self-paced learning

Dynamic pace adjusted to knowledge level

Customised learning path for each user

Identifies and addresses knowledge gaps

Measures actual competence, not just activity

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Course Overview

Knowing when and how to make a Suspicious Activity Report is one of the most sensitive parts of AML compliance for law firms. This course gives fee earners, supervisors and MLROs a clear, practical framework for handling suspicion—recognising when the reporting threshold is met, escalating internally, and engaging with authorities without tipping off clients. Using a Greenbridge property scenario, learners see how ordinary work can cross into SAR territory and what happens next.

Who Should Take This Course

Fee earners and front-line staff across all practice areas

Supervisors and team leaders who review files and manage difficult client conversations

MLROs, deputy MLROs and compliance/risk professionals

MLROs, deputy MLROs and compliance/risk professionals · Onboarding and operations staff who may first spot concerning payment routes or patterns

What You'll Learn

  • The purpose of SARs in legal practice and how they sit between AML law, criminal law and professional duties to clients
  • A detailed Greenbridge Holdings case study, where unexplained third-party credits, opaque business models and last-minute payment changes raise suspicion
  • The legal threshold for suspicion: “knows, suspects, or has reasonable grounds to suspect”, and how this differs from vague unease or full proof
  • Typical triggers that move a matter into SAR territory: inconsistent stories, unevidenced source of funds or wealth, concealment of ownership, evasive behaviour and recognised typologies
  • How internal reporting works in a law firm: the role of fee earners, supervisors and the MLRO, and what a good internal report should contain
  • The MLRO’s role in deciding whether to submit a SAR and whether to seek a defence against money laundering (DAML) before proceeding
  • What information an external SAR should contain so that law enforcement can understand who is involved, what is suspicious, and what activity is planned or has occurred
  • What happens after a SAR is made: waiting periods, DAML responses, and decisions about proceeding, pausing or exiting the relationship
  • Tipping-off risks and how to communicate with clients and third parties in neutral language while a SAR is under consideration
  • Record-keeping requirements around SARs: internal reports, MLRO decisions, SAR references, authority responses and outcome notes
  • The distinct responsibilities of fee earners, supervisors and MLRO/compliance in ensuring suspicions are not ignored

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Key Learning Outcomes

By the end of this course, learners you will be able to:

  1. Explain what a SAR is, why it is required, and how it fits within AML obligations and client duties.
  1. Recognise when suspicion (or reasonable grounds to suspect) has been reached and distinguish this from mere discomfort.
  1. Prepare clear, factual internal reports to the MLRO that set out who is involved, what is happening, and why it is suspicious.
  1. Understand how an MLRO evaluates internal reports, decides whether to submit a SAR, and when to request DAML.
  1. Describe the key elements of a strong external SAR narrative, including activity, red flags and actions taken or proposed.
  1. Manage transactions and client communications after a SAR, including pausing work when required and avoiding tipping off.
  2. Fulfil their own role—fee earner, supervisor or MLRO—in a way that supports timely reporting and protects both the firm and ongoing investigations.

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Why This Course Matters

SARs are where AML compliance becomes most exposed: get them wrong and a firm risks both regulatory sanction and criminal liability. Yet many lawyers feel uncertain about what truly counts as suspicion, how to report it, and what they can safely say to clients while a SAR is considered. This course builds confidence and consistency around SAR decision-making, ensuring that suspicions are taken seriously, reported properly and managed lawfully from first concern through to final outcome.

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Please email for buying assistance: hello@denkenknowledge.com

What people say

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Frequently asked questions

Have a look at most frequently asked questions.

Is there a minimum or maximum team or class size?

Denken is designed to support teams or classes of any size, whether you’re a small firm or a large organisation. There’s no minimum or maximum: we adapt to your needs.

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Yes, you can pay for our courses and series of modules via Invoice. Please use the Contact form to make an enquiry, and we will email over an invoice when you're ready. Please note, we do not accept purchase orders as a payment method.

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Yes, we use Stripe for online credit card payments. Details will be visible on your invoice.

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Yes, we are here to help every step of the way, both as a client and a learner using our platform.

How do I access course materials?

Course materials can be accessed through our platform dashboard once you or your learners have been enrolled. Each learner will receive a Welcome Email with full instructions.

Can I get a refund for a course?

You may cancel your course booking at any time before payment has been made by emailing us at hello@denkenknowledge.com. Once you have accessed your course on our platform no refunds will be made.

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