7 Essential SAR narrative tips to ensure your reports drive action

Below are some best practices for SAR narrative writing to help your SARs get noticed and make maximum impact on the fight against financial crime—all while ensuring that your regulators are happy.

1. Write to your audience. Remember, you’re writing for law enforcement. While it is true that you are writing SARs for your auditors, regulators, and your financial institution, your primary audience is law enforcement. They are the ones using the information to catch the bad actors and keep illicit funds out of your financial institution. The other readers are merely making sure your SARs are being correctly filed.
2. Grab attention with a strong opening line. Get the reader’s attention early on in your SAR narrative. Your first sentence must be captivating to keep the reader’s attention. Tell your story in plain language, and be careful with acronyms and financial institution jargon. Spell out these terms for the law enforcement personnel reading it. If your case is especially nefarious, it may be best to call law enforcement.
3. Cut out fluff. Be concise, thorough, and accurate. Leave out any unnecessary information and reread the narrative before filing. Delete any extra “fluff” that will hide the critical case information and lose your reader’s interest. This is a detailed, factual document, not a creative writing essay.
4. Use keywords to boost SAR discoverability. SAR keywords not only make it easier for law enforcement to pull pertinent information, but they also satisfy FinCEN requests to add specific keywords in the narrative, such as “human trafficking,” “funneling,” “political corruption,” etc.
5. Avoid redundancies. Don’t be repetitive. While it’s important to always include the who, what, when, where, and how of the situation—and why you believe the activity is suspicious—you shouldn’t need to rehash this information in your SAR narrative. If the information in a SAR box does not explain your story further, such as a subject’s driver’s license number, don’t repeat it.
6. Stay updated on regulatory guidance. Use the most recent regulatory SAR guidance. Where conflicting guidance is concerned, use the most recent guidance from both FinCEN and the FFIEC to satisfy regulatory requirements – use SAR form instructions, the 2012 SAR form Q&A (FIN-2012-G002), the 2014 FFEIC Exam Manual's Appendix: L on SAR Quality Guidance.
7. Balance compliance with impact. Always follow your regulator’s instructions. While your regulator may want something in the SAR narrative that you believe will not assist law enforcement, pick your battles. A strong relationship and open communication with your regulator are healthy and critical for a robust AML/CFT program. SAR narrative writing is probably not a battle you need to win.

Writing a SAR narrative that gets noticed by law enforcement is a skill every AML/CFT investigator should have and one of the more critical aspects of an AML/CFT professional’s job duties. By keeping your audience in mind, crafting concise and accurate narratives, and utilizing keywords effectively, you can increase the chances of your SARs being read and acted upon. Remember, the goal is to provide law enforcement with the information they need to act against illicit activity while maintaining compliance with regulatory expectations.

Follow these tips and stay informed on the latest SAR guidance to strengthen both your investigative impact and your AML/CFT program's ability to uncover and stop potential financial crime. Your resources and knowledge are valuable, so make them count.