The Dynamics of a Well-Written Suspicious Activity Report Narrative

Financial Institutions

January 01, 2016

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A system providing for proper Suspicious Activity Report (SAR) completion and timely filing is an indicator of a strong Bank Secrecy Act (BSA) program that incorporates policies, procedures, and processes to properly monitor for suspicious activity.  Just as important as the data input in Parts I-IV of the SAR is, so too is the written completion of Part V:  Suspicious Activity Information—Narrative.  SAR narratives are useful in describing information about specific activity for possible law enforcement investigation.  In addition, the Financial Crimes Enforcement Network (FinCEN) utilizes BSA data in its analytical tools to provide law enforcement, regulatory agencies, and the financial services industry important information and guidance on broader regional and systemic threats and trends.  Clearly written narratives have helped identify mortgage fraud, identity theft, and terrorist financing schemes at the institution level, as well as reflect how pervasive illicit behavior has become industry-wide.  A sufficiently written narrative should, therefore, be a focus of a BSA program’s suspicious activity monitoring.

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