SAR/STR Filing Best Practices for EU Banks Under 6AMLD and AMLA
Suspicious Activity Reports (SAR/STR: reports to authorities on suspected money laundering or terrorist financing) are critical to EU anti-money laundering efforts, but they're also a major pain point. The real friction is preventable errors and thin narratives that FIUs (Financial Intelligence Units: national authorities that receive SAR/STRs) flag as unhelpful. A modern KYC and AML platform fixes this with consistent processes, data-rich cases, and built-in regulator alignment. ECB Supervisory Manual
Understanding EU Filing Requirements: 6AMLD and AMLA Timelines
National rules often require submission "without delay," while the new AML Regulation introduces harmonised obligations. Your platform should encode these rules into configurable SLAs and templates. Council of the EU press release
Current framework: Many banks operate 30-day SLAs for standard cases, but statutory duties remain "without delay" for terrorist financing. Platforms need immutable audit logs and role-based access. National FIU example
AMLA enhancements: Under AMLR, obliged entities must answer FIU requests within five working days, or within 24 hours for urgent cases. AMLA will drive common STR formats by 2026–2027. Platforms should support urgent lanes with 24-hour timers and auto-escalation. AMLR factsheet; AMLA timeline
Step 1: Standardize Alert Investigation and Triage
Banks with 95%+ acceptance rates rely on predictable case structures. FATF's digital transformation work shows systematic approaches improve risk detection and efficiency. FATF guidance
Risk tiers: Classify alerts into Urgent, High, Medium, Low using model scores. Enforce timeboxes: Urgent within 4 hours, High within 24 hours, Medium within 5 days. ECB Manual
Decisioning templates: Map decision trees to common typologies like structuring and trade fraud. Retain full data lineage. FATF guidance
Evidence collection: Auto-pull fields from KYC files, counterparties, UBO changes, sanctions screening, and blockchain analytics with GDPR controls. ECB Manual
Performance targets: 70%+ SAR customers from High/Critical tiers, under 10% manual overrides, 99.5% on-time filing. Back these with dashboards and EuReCA-aligned logging. EBA ML/TF risk
Step 2: Craft High-Quality Suspicion Narratives
Law enforcement wants actionable intelligence. Answer the five W's, quantify variance from baseline, and map to predicate offenses under 6AMLD. Council press release
Platform assist: Use narrative builders that auto-pull KYC context, risk scores, sanctions hits, and peer benchmarks. Attach documents and generate flow diagrams. FATF guidance
Avoid failures: Replace vague wording with deltas against stated income and historic patterns. Tie back to KYC files. Regulators criticise "unsubstantiated" filings. FATF guidance
Step 3: Manage Filing Timelines and Workflow Automation
Eliminate manual bottlenecks through parallelised investigation, legal review, and automated escalations with immutable audit trails. ECB Manual
Workflow: Run parallel tasks with gated approvals. Auto-escalate standard cases beyond 20 days to MLRO. Trigger red status for urgent cases exceeding 48 hours. ECB Manual
Automation: Pre-populate forms, manage timers at 50%, 75%, 90% of SLA, support e-filing, and track FIU acknowledgments. AMLR factsheet
Post-filing: Maintain 5+ year audit trails with EU data residency and version-controlled evidence. ECB Manual
Table: SAR Filing Timelines Under Current vs AMLA Regimes
| Scenario | Current (National) | AMLA/AMLR 2027 context | Quality Impact |
|---|---|---|---|
| Standard suspicion | Typically "without delay," specifics vary by FIU | Common STR format and indicators by 2026–27 | Track median cycle time |
| Urgent cases | Immediate in practice, especially for TF | FIU info-requests may require <24h response | Requires urgent-lane routing |
| Tipping-off control | Prohibited under EU law | Harmonised supervision | Access control critical |
| FIU follow-ups | Ad hoc timelines | 5 working days default, urgent <24h | Automate SLA alerts |
Sources: Council of the EU press release; AMLR factsheet
SAR Quality Metrics: What AMLA Will Emphasise
Completeness: Target 100% mandatory field population. High-quality SARs include 12–15 supporting documents. Use required-field gates. FATF guidance
Timeliness: Keep median cycle time below SLAs. Calibrate urgency to 3–5% of alerts. Use breach alerts and analytics. ECB Manual
Usefulness: Supervisors stress intelligence value over volume. Ingest FIU outcomes to prioritise investigative patterns. FATF guidance; AMLA mission
Summary: Building a High-Performance SAR Filing Operation
Quality SAR filing requires standardised investigation, evidence-rich narratives, and workflow automation. Meet "without delay" duties while preparing for AMLR's five-day and sub-24-hour FIU windows and AMLA's harmonised formats. Treat filings as a platform capability with data lineage, EU residency, and measurable SLAs. Teams investing in templates, automation, and feedback will lower rejection rates and be inspection-ready for 2027. Council press release; AMLR factsheet; AMLA mission
Platform checklist: KYC onboarding with AI verification, risk scoring, transaction monitoring, sanctions and PEP screening, UBO mapping, guided SAR workflows, regulator templates, EU data residency, GDPR and ISO 27001 controls, and automation.