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Why Are Your SARs Not Getting Read by Law Enforcement? Here Are 7 Tips to Improve Your Narrative

by: Terri Luttrell, CAMS-Audit

Your suspicious activity reports (SARs) are swimming in a sea of two billion SARs filed with FinCEN each year, so how do you get your investigations noticed? BSA analysts spend hours working on an investigation; thus you want to be sure to make the most significant impact for each suspicious activity case. At our recent BAM+ User Group conference, Terri Luttrell, CAMS-Audit discussed the best tactics to get your SAR noticed while ensuring that your regulators are happy. Here are seven tips to get eyes on your SAR:

  • Law enforcement is your primary SAR audience. While it is true that you are writing SARs for your auditors, regulators, and financial institution, your primary audience is law enforcement. They are the ones using the information in them to catch the bad actors and keep illicit funds out of your financial institution. The others are merely making sure they’re being correctly filed.
  • Get the reader’s attention early. Your first sentence must be captivating to keep the reader’s attention. Tell your story in plain English and be careful with acronyms and financial institution jargon. Spell it out for the law enforcement personnel reading it. If your case is one of especially nefarious activity, pick up the phone and call law enforcement. Build that partnership and let them know what you’ve found.
  • Be concise, thorough, and accurate. Leave out any unnecessary information and reread the narrative before filing. Delete any extra “fluff” that will hide the important case information and lose your reader’s interest. This is a detailed, factual document, not a creative writing essay.
  • Use keywords. Keywords not only make it easier for law enforcement to pull pertinent SARs, but it also satisfies FinCEN requests to add certain keywords in the narrative, such as “human trafficking,” “funneling,” “political corruption,” etc.
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  • Don’t be repetitive. Tell your story and always include the who, what, when, where, how, and why you believe it is suspicious. If the information in a SAR box does not explain your story further, such as a subject’s driver’s license number, don’t repeat it.
  • Use the most recent regulatory SAR guidance. To satisfy regulatory requirements, where conflicting guidance is concerned, use the most recent guidance from both FinCEN and the FFIEC.
    • FinCEN – use SAR form instructions and the 2012 SAR form Q & A (FIN-2012-G002)
    • FFIEC – 2014 Exam Manual, Appendix: L, SAR Quality Guidance
  • Always follow your regulator’s instructions. While your regulator may want something in the SAR narrative that you believe will not assist law enforcement, pick your battles. A strong relationship and open communication with your regulator is healthy and critical for a strong BSA Program. Therefore, SAR narrative writing is probably not a battle you need to win.
SAR filing is one of the most important aspects of a BSA professional’s job duties. If you follow these tips, law enforcement will more likely read your SARs and possibly open an investigation or use them in an active case. Your resources and knowledge are valuable, so make them count!
About the Author

Terri Luttrell, CAMS-Audit

Terri Luttrell is a seasoned AML professional and former director and AML/OFAC officer with over 20 years in the banking industry, working both in medium and large community and commercial banks ranging from $2 billion to $330 billion in asset size. She has successfully worked with institutions in developing BSA/OFAC programs, optimizing various automated solutions, and streamlining processes while ensuring all regulatory requirements are met. As the Senior Manager of Strategy and Engagement at Abrigo, Terri provides insights that contribute and support long-term banking strategies based on analysis of market and industry trends, competitor developments, and financial and regulatory technology changes. She is an audit-certified anti-money laundering specialist and a board member of the Central Texas chapter of the Association of Certified Anti-Money Laundering Specialists (ACAMS). Terri earned her bachelor’s degree in business administration, specializing in business and finance, from the University of North Texas.

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