A payment is held. An account is closing. Documents are being requested. A complaint has been escalated. In each case a customer asks why, and somebody has to answer within the tipping-off prohibition. This pack sets out the wording that creates exposure, the wording that does not, and the reason each line sits where it does.
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What this is, and what it is not. This pack is editorial analysis of the statutory test applied to ordinary phrasing. It is not a legal opinion, it is not software output, and it does not replace your MLRO. Firms differ in risk appetite, in jurisdiction, and in what their standard customer communications already say. Calibrate every line with your MLRO and your own legal advice before it reaches a customer.
Three features of the legal test are routinely misunderstood inside firms, and each one widens the exposure well beyond the small number of people who know a report has been made.
You do not have to mention a report. Section 333A of the Proceeds of Crime Act 2002 covers disclosing that a money laundering investigation is being considered or carried out, and Article 39 of Directive (EU) 2015/849 covers disclosing that an analysis is being or may be carried out. Neither provision requires the word report to appear anywhere.
Prejudice does not have to happen. The test is whether the disclosure is likely to prejudice an investigation, so prosecutors do not have to show that one was actually damaged.
Intent is irrelevant. There is no requirement to show that the person meant to help anybody. That is the point that matters for anyone designing a control, because it means the profile of the person who commits the offence is a conscientious employee answering a question as helpfully as they can, in a reply that takes ninety seconds.
Every table in the pack has the same three columns. The third one is the part that travels, because it lets you apply the reasoning to wording we did not anticipate.
| Creates exposure | Lower risk | Why the difference matters |
|---|---|---|
| “It is with our financial crime team.” | “The payment is going through a standard internal review.” | Naming the function identifies the nature of the review. The customer does not need to hear the word report to draw the inference. |
| “We cannot continue the relationship following a review of your account activity.” | “We have decided to end the relationship. We do not provide reasons for commercial decisions of this kind.” | Linking the exit to a review of activity supplies the causal link. A generic formula applied to every exit does not. |
| “I can see the notes but I am not allowed to tell you what they say.” | “I do not have anything further I can share on this.” | Stating that there is something you are forbidden to say confirms that something exists. That inference is the disclosure. |
Regulation (EU) 2024/1624 replaces the directive with a single directly applicable rulebook. Article 73 restates the prohibition in wider terms.
It covers disclosing that transactions or activities are being or have been assessed, under Article 69. The categories of person bound are the same as the directive's. What is new is the covered fact: the directive attaches the prohibition to the transmission of a report and to an analysis being carried out, and the Regulation adds the assessment itself, which happens before any report exists. The prohibition currently bites at the point of reporting. Under the Regulation it bites at the point of assessment, which is earlier and far more often in view of customer-facing staff.
The practical consequence is that wording which is defensible today because no report existed yet will not be defensible then. Firms that fix their templates in 2026 will not have to do it again under time pressure.
Compliance and MLRO functions who need an agreed wording standard to hand to the front line, and the teams who actually write the reply: payment operations, onboarding, customer support, relationship management and complaints. It assumes no legal background and it is meant to be sayable out loud, because wording that is legally impeccable and socially impossible does not survive contact with an angry caller.