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9 Tips to Improve Your SAR Narrative for Law Enforcement

Terri Luttrell, CAMS-Audit
May 10, 2022
Read Time: 0 min

Strategies for being a better SAR writer

With the volume of SARs law enforcement have to sift through, what can a BSA officer do to stand out?  Here are a few techniques that should help.

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Making an Impact
Effective SAR Writing for Law Enforcement: How to Get Noticed

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.

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  • Add transaction details in the attachment: Suspicious transactions must be described in the body of the narrative. However, transaction details can be overwhelming in large cases. Specific activity can be explained within the narrative using date and amount ranges. Details of each transaction are best included in an attachment, so your narrative tells a concise story. Most automated software solutions easily create transaction attachments, allowing law enforcement to download the data when they pull SARs for review. Your closing paragraph should state that an attachment is available with other supporting documentation.
  • Use the most recent regulatory SAR guidance. To satisfy regulatory requirements, where conflicting guidance is concerned, use the most recent releases from both FinCEN and the Federal Financial Institutions Examination Council (FFIEC):
  • Communicate with law enforcement partners: If your case is one of especially nefarious activity, such as human trafficking or terrorist financing, pick up the phone and call law enforcement. Build that partnership and let them know what you've found. Relationships are everything in detecting financial crimes.
  • Always follow your regulator's guidance and 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 are healthy and critical for a strong BSA Program. Insignificant points regarding SAR narrative writing are probably not a battle you need to win.

SAR filing is one of the most important aspects of a FinCrime professional's job. 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

Compliance and Engagement Director
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.

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