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.