SAR narrative tips from law enforcement

by Gaye DeCesare, AUX

The purpose of the Suspicious Activity Report (SAR) is to report known or suspected violations of law or suspicious activity observed by financial institutions. A complete, sufficient, and timely SAR can help law enforcement to initiate or supplement criminal investigations, and to identify emerging trends and patterns associated with financial crimes. And the most important part of the SAR is the narrative. A well-written narrative will tell a story that draws in the reader (in this case, a financial crimes analyst) and compels them to investigate further.

Unfortunately, many SAR forms contain incomplete, incorrect, and/or disorganized narratives, making further analysis difficult, if not impossible. Some SAR forms are submitted with blank narratives. The failure to adequately describe what makes any activity suspicious undermines the very purpose of the SAR and reduces its usefulness to law enforcement.

If you struggle with how to strike the right balance in writing a SAR narrative, you’re clearly not alone. So how do you go from Zero to Hero? Here are some tips that the Aux Compliance Team has gleaned from meetings with regulators and law enforcement officials over the years, in no particular order of importance:

  • If urgent/time sensitive, CALL law enforcement, then file. (Okay, maybe that is the most important thing)
  • Follow basic writing structure taught in school: Introduction, Body, Conclusion. Remember, you’re telling a story. Narrative is literally defined as “an account of connected events; a story.”

 

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