On Tuesday 3 November 2026 Ferrier Bank's nominated officer submits a SAR asking the NCA for a defence against money laundering (DAML) so the bank can release a customer's completion funds. The NCA does not respond. Assuming no bank holidays, when is consent treated as given?
Under POCA 2002 s335, a person who makes an authorised disclosure is treated as having consent if no notice of refusal arrives before the end of the notice period: 7 working days starting with the first working day after the disclosure. Counting from Wednesday 4 November: Wed 4, Thu 5, Fri 6, Mon 9, Tue 10, Wed 11 and Thu 12 November. The 31-day moratorium applies only if the NCA refuses consent within the notice period; silence is not a refusal.
Counting seven calendar days, or applying the moratorium when there was no refusal.
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