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AML/CFT

SAR Tips Part 1 – Secrets To Effective SAR Writing

February 1, 2018
Read Time: 0 min

Let’s talk numbers. In 2016, 2 million unique SARs were filed, equating to approximately 1,700 SARs per month per team. With more and more SARs are being filed every year, and only so many teams to review them, how can you be sure your SARs are being read?

As a BSA Officer you may often ask yourself, “What happens to my SAR once it is submitted? Is anyone even reading this information?” Well, honestly, it depends. Different SAR review teams have different goals and focus, so as a BSA Officer it is important to understand your readers and what they are looking for.

Three Types of Readers

The reality is, that with the number of SARs being filed, not all of them can be read. So first and foremost, it is important to understand who is reading your SARs. In our thought leadership webinar, Best Practices for Writing SARs, Elliott Casey, Staff Attorney for the Virginia Commonwealth’s Attorneys’ Services Council, outlines three different types of SAR readers.

  1. SAR Review Teams: Review large amounts of SARs in enormous data pulls, often all at once. Your SAR may get 1-5 seconds of review before it is filtered out. Teams often filter SARs based on:
    • Dollar Amount
    • Zip Codes
    •  Keywords: “Human Trafficking”, “Narcotics Trafficking”, “Terrorism”, “Money Service Businesses”, “Elder Fraud”, “Marijuana”, etc.
  2. Case Investigators: Specifically seek out SARs on a particular suspect, business, address, etc., due to a pre-existing investigation. (i.e. NSLs, 314 requests etc.)
  3. Auditors & Federal Examiners: May randomly examine your SARs and be checking for compliance with internal/regulatory controls, and may or may not be interested in the underlying case, but instead focus on your institution’s procedures and compliance.

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The Five Essential Elements of Information

Regardless of your reader, your goal is to get their attention in the first sentence of your SAR. The most important part of your SAR narrative is the beginning. Try to explain your SAR in three sentences or less.

As a BSA officer and investigator you NEED to know the who, what, when, where, and why to form a solid case and be successful in your investigation. These are also the five essential elements of information SAR reviewers look for in a SAR narrative. The method of operation (or how?) is also important and should be included in the narrative.

For example a good SAR narrative might start like this:

This SAR concerns unusual cash activity and possible attempt to avoid reporting requirements by a client in excess of $200,000 in a 45-day period. Activity is not consistent with the Customer’s stated business of on-line T-shirt & apparel sales. Customer made successive deposits of cash between $4,000 and $9,500 at 4 different Gotham City branches, consisting of $10 and $20 denominations, using several depositors who provided inconsistent explanations for deposits.

This narrative identifies the five essential elements of information in three sentences.

  1. Who: Customer who has a t-shirt business
  2. What: He is structuring cash to avoid reporting requirements
  3. When: Over a 45-day period
  4. Where: Four different branches
  5. Why (why is this activity strange): This isn’t consistent with his business

Keep in mind, if you are using a transaction monitoring system, like BAM+, this information will be easy to identify and will make your investigation much easier. BAM+ uses machine learning to identify suspicious activity and provides transparent and easily explainable details of any suspicious activity. This type of transparency provides users with the ability to easily pinpoint why a transaction is suspicious and will ultimately save you lot of time and resources during an investigation.

As an investigator, be wary of “black box” solutions that may be highly complex and risky. “Black box” solutions must be fully understood, and as a financial crimes officer you must be able to easily justify why the software determined the activity to be suspicious, in order to avoid scrutiny from regulators and be successful in writing effective SARs.

To get more tips on writing effective SARs,  read Part II of this blog, 5 Tips to Remember When Writing a SAR Narrative or watch our thought leadership webinar, Best Practices for Writing SARs. Elliott Casey, Staff Attorney for the Virginia Commonwealth’s Attorneys’ Services Council, discusses how SAR teams operate and provides real world examples of SARs that are helpful and SARs that are not. Elliott is an experienced SAR reviewer and specializes in money laundering, narcotics, and complex white collar offenses.

For more information about how Abrigo BSA/AML software, BAM+ can reduce false positives and make your investigations more efficient visit our product page or speak with one of our experts.

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