In June, the Law Commission published a report on the UK’s anti-money laundering and terrorist financing (AML) regime in which it provided various recommendations with a particular focus on the system of suspicious activity reports (SARs).

Generally, the proposals are tweaks of the existing regime rather than wholesale reform.

Accountants may be particularly disappointed that the Commission did not recommend an amendment to legislation in order to statutorily define ‘suspicion’ in the context of SARs.