Industry Circulars

Industry Circular No: 02 of 2026

Commencement of Suspicious Activity Report (SAR) Quality Feedback

1. The Financial Investigation Agency (the “Agency”) wishes to advise all reporting entities that, effective Wednesday, 8 July 2026, it will commence providing feedback on the quality of Suspicious Activity Reports (SARs) submitted to the Agency.
2. This initiative forms part of the Agency's ongoing efforts to enhance the quality, completeness, and usefulness of intelligence received from reporting entities and to strengthen the effectiveness of the Territory's Suspicious Activity Reporting regime.
3. The Agency will provide quality feedback only in circumstances where a SAR is identified as containing deficiencies, omissions, inconsistencies, or information gaps that may adversely affect the Agency's ability to effectively analyse the report. Quality feedback will not ordinarily be provided where a SAR meets the Agency's expected reporting standards.
4. Quality feedback will be provided to the reporting entity through the AMLive reporting platform. Reporting entities are therefore encouraged to regularly monitor AMLive for any feedback relating to SARs submitted to the Agency. 
5. Feedback may relate to matters including, but not limited to:
   1. Insufficient or incomplete suspicious activity narratives;
   2. Inadequate articulation of the reasons for suspicion;
   3. Missing, inconsistent, or unclear information relating to subjects, accounts, transactions, or associated entities;
   4. Insufficient supporting documentation or contextual information; and
   5. Other deficiencies that limit the Agency's ability to conduct effective analysis.
6. The purpose of the feedback is twofold. Firstly, it is intended to notify reporting entities of deficiencies identified within a submitted SAR and, where appropriate, provide an opportunity for those deficiencies to be remedied through the submission of additional information, clarification, or supporting documentation. Secondly, it is intended to assist reporting entities in improving the quality, completeness, and effectiveness of future SAR submissions.
7. Where quality feedback is received, reporting entities should review the matters identified and take reasonable steps to address the deficiencies noted by the Agency. Any recommendations provided should also be incorporated into future SAR submissions and internal reporting processes to enhance the overall standard of SAR reporting.
8. The Agency recognises the important role reporting entities play in the Territory's anti-money laundering, counter-terrorist financing, and counter-proliferation financing framework. High-quality SARs support more effective analysis, facilitate the development of actionable financial intelligence, and strengthen the ability of competent authorities to detect and investigate criminal activity.
9. The Agency appreciates the continued cooperation of reporting entities and looks forward to working collaboratively with the industry to further strengthen the effectiveness of the Territory's SAR reporting framework.
10. For further information, please contact the Agency at:

The Financial Investigation Agency
Ritter Building
Road Town, Tortola VG1110
British Virgin Islands
[email protected]