OPBAS SAR Project Phase 1 Findings: What They Mean for PBSs
Last week the Office for Professional Body Anti-Money Laundering Supervision (OPBAS) published its Phase 1 findings from its Suspicious Activity Report (SAR) project. The report sheds light on how Professional Body Supervisors (PBSs) are currently managing their responsibilities around SAR quality and supervision — and where there is still considerable room for improvement.
In this blog, we summarise the key findings, the actions OPBAS is taking, and what PBSs and supervised firms should be considering in response.
Why SARs Matter
Suspicious Activity Reports are a cornerstone of the UK's anti-money laundering (AML) regime. High-quality SARs provide critical intelligence to law enforcement agencies, helping to identify and disrupt criminal activity.
PBSs, as supervisors of firms in sectors like law and accountancy, have a responsibility not just to ensure SARs are submitted where appropriate, but also to support their supervised populations in making those reports as useful and complete as possible.
What OPBAS Found
OPBAS’s analysis revealed several key concerns:
Limited SAR Review by PBSs: Some PBSs did not request access to SARs from their supervised firms, meaning they had no way of assessing SAR quality. In some cases, SARs were requested but not provided.
Minimal Sample Sizes: Where PBSs did conduct reviews, the volume assessed was often very low — typically one SAR per reporting entity per year.
Lack of Clear Guidance: There was inconsistency in the information PBSs provided to their supervised populations about record-keeping and SAR submission expectations.
Missed Opportunities for Collaboration: While some PBSs engaged with key partners like the UK Financial Intelligence Unit (UKFIU), this was not consistent across the sector.
Actions Taken by OPBAS
In response, OPBAS has started to:
Engage with PBSs who lacked a clear rationale for their SAR quality assessments.
Encourage better sample sizes and more risk-based approaches to reviewing SARs.
Highlight the need for clear record retention guidance to be provided to supervised firms.
Work with sector Affinity Groups to understand challenges and shape next steps collaboratively.
Implications for PBSs
The findings and subsequent actions signal a growing expectation from OPBAS that PBSs must take a more proactive, structured approach to SAR supervision. In particular:
PBSs should have a documented, risk-based rationale for how and why they review SARs, including the sample size chosen.
Training and guidance for supervised firms need to go beyond legal obligations and actively support higher quality, actionable SAR submissions.
Record-keeping practices must be improved, with clear advice to firms on what should be retained to support any future review.
Collaboration with external partners like the UKFIU and law enforcement should be actively pursued.
Implications for Supervised Firms
The growing expectations on PBSs from OPBAS means that supervised firms should in turn expect enhanced scrutiny from their PBS. This brings additional risks, including the risk of regulatory censure.
Are you ready for such scrutiny? Would your SARs stand up to examination by your PBS?
What Happens Next
OPBAS has announced several next steps, including:
Hosting a SARs Roundtable with key stakeholders such as HMRC, the Gambling Commission, UKFIU, and Affinity Group Chairs.
Conducting a targeted assessment of SAR quality across a sample of PBSs.
Continuing to put pressure on PBSs to enhance the quality and effectiveness of SAR-related supervision.
PBSs should view this as an opportunity to raise standards. Enhancing SAR quality not only meets regulatory expectations but also strengthens the wider fight against financial crime.
If you would like support in reviewing your SAR processes, training your teams, or preparing for upcoming OPBAS engagement, please get in touch at contact@avyse.co.uk.