Know your SAR narrative audience
Remember, it is not your objective to prove that illegal activity occurred but to outline why it is considered suspicious. Consider whether a person reading the narrative could clearly understand the activity that happened and why it triggered alarm bells. The “why” description is most effective in the opening paragraph to quickly establish why the SAR was filed in the first place.
It is essential to remember your audience when writing your SAR narrative. The point of a SAR is to alert law enforcement to suspicious activity, so law enforcement should be your key audience. While regulators can penalize institutions for poor SARs, and their opinions significantly impact your financial institution, it is best to write SARs as if speaking to law enforcement. That means avoiding financial institution acronyms and other industry jargon that law enforcement officials may not be familiar with.
Here are a few more considerations for your SAR narrative writing:
- Remember that information provided in other sections of the SAR does not need to be repeated in the narrative unless it is necessary to provide a clear and complete description of the suspicious activity.
- If you need to submit a corrected or amended report, complete the report with whatever corrections or amendments were required. Describe the modifications or amendments at the beginning of the narrative and be as precise as possible.
- If applicable – be proactive and contact local law enforcement, especially if you are filing a susceptible type of SAR, such as potential terrorist financing activity.
- Remember to utilize the FinCEN keyword requests in the narrative. Keyword analysis has allowed FinCEN and law enforcement to map trends and commonalities in SAR narratives.
- Continuing activity SAR narratives: When filing a continuing SAR, address and identify the previous SAR dates with a concise overview of the activity filed on those SARs. This is especially important if the current SAR filing is not for the same reason/activities as previous SAR filings. You do not have to include the entire narratives of the prior SARs.
- Be sure to keep up to date with FinCEN regulations and guidance.
- Lastly, open a line of communication with your regulator or auditor and keep them informed on your SAR narrative practices. They may be able to help craft better language or help with a narrative template to ensure your continued success. Building those relationships is critical to developing a sound AML/CFT program. Indicate if there is any litigation related to the activity by specifying the name of the litigation and the court where the action is pending.
What AML software lets community banks file SARs and CTRs directly to FinCEN?
Abrigo BAM+ provides community banks with an end-to-end AML/CFT workflow that includes transaction monitoring, investigations, case management, customer due diligence, and direct filing of SAR and CTR batches to FinCEN.
Regulatory filing begins well before a report is submitted. A typical SAR process includes:
Reviewing alerts and relevant transactions
Gathering customer and account information
Documenting investigative findings
Determining whether activity warrants a SAR
Drafting and reviewing the SAR narrative
Completing required approvals
Submitting the report and maintaining supporting documentation
SAR narrative writing is one part of this larger investigation and filing process. Connecting case information, documentation, narrative review, and regulatory reporting can reduce manual handoffs and make it easier for reviewers to follow the facts supporting a filing decision.
Connecting SAR narrative review to direct FinCEN filing
Once an investigation and review are complete, direct filing can reduce additional administrative work. BAM+ allows financial institutions to file SAR and CTR batches directly to FinCEN and receive acknowledgement of batch uploads within the system.
For community banks with lean AML/CFT teams, a connected workflow can also reduce the need to move information between separate systems, re-enter information into regulatory reports, and manually track filings after submission.
Direct electronic filing does not replace staff judgment or established review and approval processes. Investigators and BSA officers remain responsible for evaluating suspicious activity, reviewing regulatory reports for accuracy, and following applicable policies and procedures.
SARs and CTRs also have different purposes and reporting requirements. An integrated AML/CFT platform does not change those distinctions. Instead, it can help teams manage investigation, review, filing, and recordkeeping within a more connected process.
Improve suspicious activity report writing with a connected workflow
Suspicious activity report writing depends on both narrative quality and the process surrounding it. Investigators need access to the right customer and transaction information; reviewers need a clear way to evaluate the SAR narrative, and approved reports need an efficient path to filing and recordkeeping.
For community banks, connecting investigation, documentation, approval, and direct FinCEN filing can reduce unnecessary administrative steps while keeping staff judgment at the center of the process.
Technology should support, not replace, the expertise of investigators and BSA officers. A connected AML/CFT workflow can help teams spend less time moving information between systems and more time producing accurate, useful regulatory reports for law enforcement.
