Disclosing Suspicious Activity Reports in civil litigation
The Government has recently published Circular 003/2021 clarifying how Anti-Money Laundering Suspicious Activity Reports (SARs) should be disclosed in civil litigation. The Circular provides important guidance for institutions who raise SARs (reporters) to the National Crime Agency and need to disclose the SAR in litigation. However, the guidance is in very general of terms and leaves some specific circumstances unaddressed.