Overview

On 4 February 2010 the Court of Appeal handed down judgment in Shah v HSBC Bank Plc, paving the way for disgruntled customers to challenge banks who refuse to process transactions pending the response to a suspicious activity report ("SAR") made to the Serious & Organised Crime Agency ("SOCA").

Previous court decisions on this issue have been for the most part "bank friendly". But this latest decision will force banks to review their reporting systems and processes and to ensure they capture sufficient data about the basis of their suspicions.

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