FinCrime professionals spend hours working on SAR narratives, sometimes days for complex investigations. Suspicious activity investigations are critical to safeguarding the U.S. financial system from money laundering, terrorist financing, fraud, and other illicit financial transactions. Unusual activity going undetected can have devastating social and economic effects, and it is crucial in protecting the safety and soundness of our financial institutions.
Suspicious activity reports (SARs) can easily get lost in the millions of SARs filed with FinCEN each year, so how do you get your investigations noticed? Financial institution resources are valuable, and you want to be sure to make a significant impact on each suspicious activity case. Here are ten tips to get eyes on your SARs:
- Law enforcement is your primary SAR audience: While it is true that you are writing SARs for your auditors, regulators, and your financial institution, the primary audience for SARs is law enforcement. Federal and local law enforcement uses the information to catch the bad actors and keep illicit funds from your financial institution. The other audiences are merely making sure they're being filed correctly.
- Get the reader's attention early: Your opening paragraph must be captivating to keep the reader's attention. Summarize what occurred and WHY you believe the activity to be suspicious in a few sentences. You don't have to know that a crime has been committed or which crime it might be, but there is a reason that the transaction(s) caught your attention, so state that in the summarized opening paragraph.
- Describe who, what, when, where, how, and why: When describing the details of the activity in the body of the narrative, be sure to explain who conducted the transactions, what type of transaction(s) occurred, and when, where and how the activity was performed. Tell your story in plain language and be careful with acronyms and financial institution jargon. Spell it out for your law enforcement audience.
- Be concise, thorough, accurate, and organized: Organize your SAR narrative with an opening, a detailed body, and a closing paragraph. Read and review your final narrative and leave out any unnecessary information. Reread the narrative before filing. Any extra "fluff" will hide the vital case information and lose your reader's interest, so be sure to be concise. A SAR is a detailed, factual document, not a creative writing essay. Don't lose the forest for the trees.
- Use keywords: Keywords not only make it easier for law enforcement to pull pertinent SARs it also satisfies FinCEN requests to add specific keywords in the narrative, such as "human trafficking," "funneling," "political corruption," etc. FinCEN publishes the complete list of keyword requests on their website and can be found here.