Recently, Alessa hosted a webinar on the best practices for writing Suspicious Activity Reports (SAR). I want to share with you a number of best practices that go along with SARs if they are to be an effective tool for both your Financial Institution (FI), and for law enforcement.
The webinar was presented by Laurie Kelly, who has spent the last 35 years as an expert in the fields of accounting, finance, risk management, and regulatory compliance.
For CAMLOs and experienced members of a compliance team, this may seem overly simple – but that is the point Laurie wanted to make. Keep it simple, straightforward and targeted for the audience you need to reach.
The key is remembering who your main readers of SARs will be – SARs need to be a clear and concise tool that helps law enforcement to immediately understand the issue so they can deal with it. That means avoiding long, meandering explanations – get to the point and ensure that point is made early in the SAR.
As with any story, the narrative is important. I think it is vital to heed Laurie’s advice on writing SARs. It is not just a matter of populating boxes on a form.
Form fields, checkboxes and dropdown lists are necessary as they capture foundational information on the subject and the type of activity, Laurie said. They also make data capture and analysis more robust and granular and should be used judiciously.
While that information is important, the SAR narrative remains key as it grabs the reader’s attention, describes the nuances and gives you the opportunity to use keywords for data flagging.
SAR Writing Tips
Let’s break it down into simple terms and look at the best practices for writing effective SARs:
- Summarize the activity, how it was detected, and why it’s suspicious in the first sentence (or two)
- Describe elements not reflected in the names and numbers
- Behavior or appearance
- Comments made to bank personnel
- Explain why activity is out-of-pattern
- Explain any unusual transaction characteristics: amounts, timing, text messages on wire transfers
- Use simple, concise, active tense
- Repeat information already reflected in other parts of the form
- Provide lengthy lists of transaction details
- Use verbose language and/or passive tense, such as “in the amount of” or “for the benefit of”
- Provide too little information
Tips For You to Help Your Audience
- Your SAR will be read, so write for your reader – Law Enforcement
- Describe the nuances not reflected in the checkboxes and fill-in fields
- Make your narrative clear, concise, and logical
- Know FinCEN’s keywords and use them whenever applicable
- Use the attachment feature
- Distinguish “new” vs. “continuing activity” reports as it makes most sense
- Explore using a Case Report for comprehensive supporting documentation
- SARs make a tremendous impact on fighting crime
If you follow these best practices, you will help fight financial crimes by giving law enforcement the best tips, or leads, possible. In 2018, there were 10,812 SARs filed every day. That means there is some competition to ensure yours gets noticed, and the criminals will be put in the spotlight.
For additional information view our SAR resources:
- An Overview of Suspicious Activity Reports
- Effective SAR Writing Webinar and SAR Narratives
- How to Write SAR Narratives
- Case Management and Tracking For Suspicious Activity Reports