SAR narrative writing: Best practices for writing suspicious activity reports

The purpose of a strong SAR narrative and knowing 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 susceptible type of SAR, such as potential terrorist financing activity.
• 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.