Suspicious Activity Reports (SARs) & DAML
When staff suspect money laundering they report internally to the firm's nominated officer/MLRO, who decides whether to file a SAR with the UK Financial Intelligence Unit (UKFIU) at the National Crime Agency. A Defence Against Money Laundering (DAML) - the regime formerly called 'consent' - is a specific type of SAR asking the NCA for a defence before dealing with property the firm suspects is criminal. Reporting is a duty under the Proceeds of Crime Act 2002, and warning the customer can itself be a criminal 'tipping-off' offence.
SARs are made under Part 7 of the Proceeds of Crime Act 2002 (POCA); the terrorist-financing equivalent is under the Terrorism Act 2000.
A DAML (Defence Against Money Laundering) is requested when a firm intends to deal with property it suspects is criminal and wants a defence to the principal money-laundering offences (POCA ss 327-329).
After a DAML request the NCA has a 7-working-day notice period to grant or refuse a defence; if it does not respond, consent is deemed given.
If the NCA refuses, a 31-calendar-day moratorium period begins during which the firm must not proceed; extensions can be granted by a court up to a maximum of 186 days.
The DAML reporting threshold for deposit-taking bodies and certain firms was raised from GBP 250 to GBP 1,000 in January 2023 (POCA s 339A), reducing low-value 'consent' reports.
Tipping off - disclosing that a SAR has been made in a way likely to prejudice an investigation - is a separate offence under POCA s 333A; the NCA cannot grant a defence for it.
Failure by a person in the regulated sector to report where there are reasonable grounds to suspect can itself be an offence (POCA s 330).
Casinos are in the regulated sector, and remote and non-remote gambling operators must file SARs (and DAMLs where they intend to pay out or process funds they suspect are criminal) via the operator's MLRO to the UKFIU. Because a payout, refund or account closure could 'deal with' criminal property, operators often submit a DAML before releasing funds, and must avoid tipping off the customer when doing so.
Reference, not advice. This is a teaching summary of the AML framework — not legal advice, and not an operational compliance procedure. Confirm requirements against the primary regulator and your own counsel.