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SAR Writing: Best practices for a strong AML/CFT program

Jessica Corey, CAMS
February 24, 2023
Read Time: 0 min

Strategies for clear, concise SAR writing

How can BSA officers make their SARs stand out to law enforcement? These suggestions for structuring and writing SARs can help.

You might also like this webinar, "Best Practices for Writing SARS."

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Critical reporting

The importance of comprehensive SAR writing

Back in elementary school, most of us were taught that a good story includes the who, what, where, when, why, and how of the events it describes. But when AML professionals sit down to write a good narrative for a suspicious activity report (SAR), the task can seem overwhelming. How can financial institutions utilize these storytelling principles in their SAR narrative writing to produce clear reports?

The Federal Financial Institutions Examination Council (FFIEC) BSA Examination Manual states that the SAR narrative section is “critical.” The care with which the SAR is written may make the difference in whether the described conduct and its possible criminal nature are clearly understood by law enforcement. Thus, failing to explain the factors that make a transaction or activity suspicious can undermine the purpose of the SAR. Information provided in SARs allows FinCEN and federal banking agencies to identify emerging trends and patterns associated with financial crimes.  

Save time by direct filing your SARs and CTRs with FinCEN.

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Making an impact

Structure and best practices for SAR writing

  • The following prompts can help organize your SAR narrative following the approach of describing the who, what, where, when, why, and how:

    • Who conducted the activity? Describe any details not outlined in Part 1 of the SAR.
    • What specifically happened to help determine a SAR filing? Describe transactions, interactions, or activities that led to the SAR filing decision.
    • Where did the activity take place? State the branch and location address of where the action took place.
    • When did the activity occur? Clearly state if this was a one-time occurrence or a pattern of activity, including a clear timeline.
    • Why is the SAR being filed? As succinctly as possible, describe why the activity is considered potentially suspicious.
    • How did the activity occur? Describe the transactions or how the pattern emerged.

    The first section of the narrative should be where you draw the reader’s attention to the suspicious activity. It is unnecessary to start any narrative with the financial institution’s history, what alert number triggered the investigation or anything else not about the potential activity in question. Provide information about the financial institution’s business policies and practices only if necessary for a complete understanding of the suspicious activity.

    Be concise when relaying transaction details – it is okay to summarize many of the transactions in your SAR and provide more specifics about each transaction in the transaction attachments or supporting documents. Be sure to state in the closing paragraph that any supporting documents are available for review upon request from law enforcement. Retain the documentation for five years in case it is requested.

Further considerations

The purpose of SARs and writing to your 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 particularly sensitive type of SAR.
  • 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.


Staffing for better SAR writing

Proper staffing ensures regulatory deadlines are met while SAR quality stays intact. If your financial institution is struggling with backfills or other staffing challenges, Abrigo Advisory Services stands ready to help you with your SAR filings. Advisory services can help banks work through a backlog of alerts or cases, write SAR narratives, create a SAR narrative template that works for your institution, or draft policies and procedures for your alert-case-SAR triage workflow. 

Financial institutions spend significant hours crafting SARs, and lightening the load on staff can lead to more thorough SAR writing and higher likelihood that your efforts will be noticed by law enforcement.

Check out this SAR writing checklist for essential elements of a compelling SAR narrative.

About the Author

Jessica Corey, CAMS

Risk Management Consultant
Jessica Corey has over 17 years of experience in BSA/AML Operations and Compliance in the banking industry, working both in medium & large community and commercial banks.  She started her banking career in retirement services, moving to deposit operations and the compliance/fraud arenas where she was a BSA/AML Analyst/Investigator and

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