Financial Crime World

Submission of Suspicious Activity Reports by Legislation Reveals Insights into Global Criminality

A recent report from the Gibraltar Financial Intelligence Unit (GFIU) has shed light on the global scope of criminal activity, with a significant number of Suspicious Activity Reports (SARs) submitted to authorities across the world.

Global Reach of Criminal Activity

According to the report, a total of 2,661 SARs were submitted in 2021, with the majority being dual- disclosed to both the GFIU and foreign Financial Intelligence Units (FIUs).

Top Three Countries for Criminal Activity

The top three countries where criminal activity took place, based on the number of SARs submitted, are:

  • United Kingdom: 642
  • Canada: 1022
  • Mexico: 987

Sectors Impacted by Suspicious Activity

The report also highlights the various sectors where suspicious activity was detected, including:

Sector Breakdown

  • Online/e-Gaming: 827
  • Distributed Ledger Technology: 98
  • E-Money: 17
  • Bank/Building Society: 34
  • Lawyer: 4

Outcomes of SARs

In terms of outcomes, the report reveals that a large proportion of SARs were dual- disclosed, with only 7% requiring further action by the GFIU.

Feedback Quality Assessment


The quality of feedback provided to the reporter was also assessed, with ratings given for four criteria:

  • Supporting documentation necessary for effective analysis
  • Presence of suspicion of predicate offence or money laundering
  • Sufficient detail on relationship with reported subject
  • Clarity and completeness of information

Areas for Improvement

The report highlights areas where improvement is needed, including inconsistencies in feedback quality. However, the GFIU has taken steps to address these issues by raising them with the Themis Improvements and Development Working Group.

Accessing the Full Report


The full report can be accessed on the GFIU’s website at www.gfiu.gov.gi.