New Threshold for Defence Against Money Laundering SAR

Please note that the thresholds for submitting a Defence Against Money Laundering (DAML) Suspicious Activity Report (SAR) will rise to £3,000 from £1,000 on 31 July 2025 in line with new legislation: the Proceeds of Crime (Money Laundering) (Threshold Amount) Order 2025.

Practices and firms will not commit money laundering offences if the value of the criminal property in the proposed transaction is less than £3,000. One aspect of this is that practices/firms can return money to a client/customer to end the business relationship without committing a criminal offence if the value of the suspected criminal property is below £3,000.

We wish to emphasise that the threshold change relevant for CLC practices relates to S.339A(6A) of the Money Laundering Regulations (MLRs) and is confined to acts done in order to terminate a business relationship (such as returning the money to a client). If the value of this money (suspected criminal property) is under £3,000 then a money laundering offence will not committed by returning the money to the client. This is quite a narrow threshold alteration and likely not relevant to most transactions that CLC practices are involved in. It would cover most payments on account. 

If the value of the suspected criminal property is above £3,000 then a DAML SAR is required in order to avoid committing a criminal offence and the usual process followed.

Please also bear in mind that this change relates specifically to making a DAML SAR. If you develop suspicions about client money that is under £3,000 then you would still be under an obligation to report this to the NCA as an intelligence only SAR (ISAR). Remember that there are no thresholds when it comes to forming suspicions and being under an obligation to report them. 

This change does not affect CLC practice’s obligations to conduct proper Client Due Diligence. 

If you have any questions about this then please contact our dedicated AML mailbox: aml@clc-uk.org