What is a SIRA marker and can it be challenged?

We regularly receive enquiries from individuals who have been adversely affected by a CIFAS marker, in circumstances where they are adamant that they have done nothing wrong. We have recently assisted one such client with the successful removal of a CIFAS marker which their bank had posted in their name.

In addition, we are being approached by individuals affected by the lesser known – but potentially equally devastating – SIRA marker. This marker could serve as a reason for the bank to close an individual’s account.

In some scenarios, a SIRA marker may be wrongfully issued against an individual, and this unfair situation can have a hugely detrimental effect for the individual concerned due to the wide-ranging, complex and adverse consequences.

Individuals are contacting us for advice on how to remove a wrongfully placed SIRA marker and what can be done to challenge the potential closure of their account by the financial institution concerned.

What is a SIRA marker?

National SIRA is a UK fraud‑prevention consortium operated by Synectics Solutions.

Member organisations across banking, insurance, telecoms and other sectors contribute and consult application and transactional data to detect the risk of fraud and flag any inconsistencies. When a member’s screening triggers any concerns, the record can be flagged on the SIRA platform so that other members reviewing future applications can see the outcome and act accordingly.

SIRA decisions commonly record a status such as “clear” or “refer”. In practice, firms also load more specific flags.

While a SIRA marker is not a determination of guilt (i.e. a criminal conviction), it signals to other members that information associated with a certain individual or business customer warrants additional checks or caution, which can cause problems for the individual concerned.

How can I find out if I am subject to a SIRA marker?

Establishing whether you have a SIRA marker against your name can be difficult. Unlike consumer credit files, SIRA data is not routinely visible on mainstream credit reports.

Absent a victim‑of‑fraud alert elsewhere, many people will only discover that an adverse SIRA entry exists after the bank closes their account or repeatedly declines their applications to open a bank account.

Can I challenge a SIRA marker?

The answer is yes – but this will depend on the facts of the case and the available evidence.

There is, however, no “quick fix”, and members are not obliged to remove a marker simply because it is inconvenient for the person in question.

In order to secure the best chance of a successful removal, individuals must demonstrate that the entry is inaccurate, unfair, disproportionate or otherwise non‑compliant with applicable standards.

Options for challenging a SIRA marker include the following:

1. Build the factual record

By way of a data Subject Access Request, obtain your SIRA data, bank statements, application forms, device/IP logs (if available) and correspondence. Where identity misuse is alleged, gather crime references, Action Fraud reports and any remedial steps you have taken.

2. Challenge the firm that asked for the marker

Write a detailed, evidence‑based challenge to the firm that requested the marker, explicitly addressing each of their concerns. Explain and correct any discrepancies (e.g. addresses, income, employment, device fingerprints) with documents rather than assertions. Ask the firm to review its decision and remove or correct the entry across SIRA.

3. Lodge a complaint with Synectics Solutions

If the firm which requested the marker refuses or fails to respond adequately, lodge a complaint with Synectics (SIRA operator) with your evidence and the final response.

Request an independent review of accuracy and fairness and, where appropriate, deletion or amendment under data protection principles.

4. Complain to the Financial Ombudsman Service

If the above steps do not resolve the issue, you can consider a complaint to the Financial Ombudsman Service (for banks and many financial firms). The Ombudsman will make a decision, having considered whether SIRA markers – such as “inconsistency” – were reasonably recorded in light of the information available at the time. We have described this process in one of our previous articles.

5. If applicable, explore litigation options

In a small number of cases, remedies may be pursued via the courts (e.g. claims for data accuracy under UK GDPR and the Data Protection Act or judicial review of decisions by a public body). These routes are fact‑sensitive and require careful assessment of prospects and proportionality.

NAVIGATING FINANCIAL INSTITUTION-RELATED CHALLENGES

What can I do to challenge a wrongful decision to close my personal and/or business bank account(s)?

We are receiving a growing number of requests for assistance from individuals who have been “de-banked” despite always acting in full compliance with the relevant bank account’s terms and conditions and all other applicable rules and regulations.

We have previously written about how bank account closures are not limited to political figures in the UK and affect many thousands of lawful individual and business customers every year.  These cases have exposed the difficult balance many financial institutions and their individual and business customers must navigate to gain and maintain access to basic banking services.

To assist those whose accounts have been closed, Gherson’s Financial Crime, Investigations and Regulatory Team have written the following articles:

• Why has my bank account been closed?
• Why has my business bank account been closed?
• 140,000 SMEs “de-banked” last year – why could I have been de-banked?
• What are the proposed new laws aimed at preventing de-banking?
• Why the proposed new laws to try and prevent de-banking to not go far enough?
• Am I entitled to a basic bank account in the UK?
• How to challenge crypto-related bank account closures?
• De-banking and crypto – will the landscape be positively changed by the introduction of new rules for both?

 Adverse information on compliance databases

We also regularly provide assistance to individuals who believe that there is incorrect and/or inaccurate data about them stored on compliance databases, which is having an adverse effect on their relationship with financial institutions, resulting in issues such as bank account closures or difficulties with opening a bank account.

We have previously written a series of articles providing a basic overview of the main functions of compliance databases such as World-Check and ways to correct personal information such databases?

HOW GHERSON CAN ASSIST

Gherson’s Financial Crime, Investigations and Regulatory Team are highly experienced in providing assistance in situations where the bank freezes or closes your account. This includes helping with submitting a request under data protection legislation, otherwise known as a Data Subject Access Request, to find out what information banks and other financial institutions may be holding about you and ascertain their decision making, and then analysing the response and assisting with any appropriate challenges.

If you have any questions arising from this blog, please do not hesitate to contact us for advice, send us an e-mail, or, alternatively, follow us on X, Facebook, Instagram, or LinkedIn to stay-up-to-date.

The information in this blog is for general information purposes only and does not purport to be comprehensive or to provide legal advice.  Whilst every effort is made to ensure the information and law is current as of the date of publication it should be stressed that, due to the passage of time, this does not necessarily reflect the present legal position.  Gherson accepts no responsibility for loss which may arise from accessing or reliance on information contained in this blog.  For formal advice on the current law please do not hesitate to contact Gherson.  Legal advice is only provided pursuant to a written agreement, identified as such, and signed by the client and by or on behalf of Gherson.

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