# Presentation: 139613

## Slide 1

## Note:  The following slides represent suggestions to enhance the writing of a SAR narrative.  This information should be used in conjunction with the instructions provided with the appropriate SAR form used by your institution & through guidance issued by FinCEN & regulatory authorities.

## The Importance of Filing a SAR

- Identifies potential & actual illegal             activity:

-   Money laundering

-   Terrorist financing

-   Other financial fraud & abuse

- 2.  Detects & prevents flow of illicit funds

- 3.  Establishes emerging threats through 	                        analysis of patterns & trends

- 4.  It’s required by law!

## #1 Rule:

- Do not assume the reader is familiar with your institution’s internal terminology, acronyms, operational processes, or has other knowledge related to the reported violation.

## The Narrative should:

- Be ***concise*** & ***clear***
- Provide a ***detailed**** description* of the known or suspected criminal violation or suspicious activity
***Identify*** the essential elements of *information* (the 5 W’s)
- Be ***chronological***** & *****complete***

## The 5 “W’s” of Information

- Who?

- What?

- When?

- Where?

- Why?

- “How?”can be important, too!

## Who is conducting the criminal or suspicious activity?

- 	Describe additional details about the suspect(s) other than those provided earlier in the SAR form (Part I for SAR-MSB, SAR-SF & SAR-C or Part II for the depository institution SAR) :

-   	Employer & occupation information

-   	Relationship between the suspect & the 		filing institution

-   	Length of the financial relationship

## What instruments or mechanisms facilitate the suspect activity/transactions?

- 	Identify & describe the transactions raising the suspicions of the financial institution. Examples include:

-   	Cash deposits and/or withdrawals

-   	Checks & other monetary instruments                	(money orders; traveler’s checks;                           	cashiers or 	bank 	checks)

## Additional types of transactions raising the suspicions of the financial institution:

-   	Wire or other electronic transfers
- 	(ATM, ACH)

-   	Cash Letters, Pouch Activity or other 	correspondent account activity

-   	Stocks, bonds or notes

-   	Casino chips or markers

-   	 Foreign currency

## When did the criminal or suspicious activity occur?

-   	If a one-time occurrence, identify
- 	the date

-   	If a pattern of activity occurred 	over 	a span of time, state when 	the activity first initiated and 	then 	describe the activity during 	the duration

-   	Identify when the activity was 	detected

## Where did the suspicious activity take place? 

- Identify the branch/department location          or locations within the institution where the activity occurred (name of branch, office or department and the street address for each)

-  Indicate if suspect transactions involve
-    other domestic or international banks &
-    identify the banks, their locations,
-    account numbers, etc.

-  Identify all account numbers & types
-    of accounts affected by the
-    transactions/activity

## Why does the institution think the activity is suspicious?

-    First, describe the filer’s type of 	institution (i.e., XYZ Bank is a 	commercial bank with 400 branches 	located in 5 northeastern states; Send 	Money Quick is an international 	money transmitter with five offices in 	metropolitan Pretend City; We Make U 	Money is a 	securities broker, etc.)

## Why does the institution think the             activity or transaction is suspicious (cont.)?

-  	Next, describe concisely but fully, why 	the institution considers the activity as 	suspicious

-  	Be sure to include any relevant 	information about suspicious customer 	activity that the institution has in its files 	at the time the SAR is filed

## How did the suspicious activity occur?

-   In a concise, accurate and logical 	manner, describe how the suspect 	transaction or pattern 	of transactions 	were completed

-  	For account activity, provide as    	completely as possible an explanation         	of the cycle of funds including the 	source of the funds in the account & 	application of those funds

## Suggested structure of                                       the narrative

- Introduction
- Body
- Conclusion

## 1. The Introduction                                                     

- Provide a brief statement of the SAR’s purpose
- Generally describe the known or               suspected violation
- Identify the date of any SARs                      previously filed on the subject & the            purpose of that SAR
- Indicate any internal investigative               numbers used by the filing institution to maintain records of the SAR

## 2. The Body 

- Provide the relevant facts about all              parties facilitating the suspect activity                   or transactions

- Answers ***Who?***

## 2. The Body (cont.)

- Identify all involved accounts and transactions in chronological order              by date and amount – do not use                  or insert tabular objects, tables, or                      pre-formatted spread sheets

- Answers

***What?***

***Where?***

***When? ***

## 2. The Body (cont.)

- Explain in detail the filer’s position that               the activity or transaction is illegal                       or suspicious

- Answers ***Why?***

## 2. The Body (cont.)

- Describe the method of operation                   of the subject:

-    Manner in which the activity and/or 	transactions were completed;

-    Any relationship to other 	transactions, accounts,   	conductors, etc.;  and

-     Subsequent results of the activity

- Answers ***How?***

## 3. The Conclusion

- Any planned or completed follow-up actions by the institution

-  Location within the institution where
-    all SAR-related records are
-    maintained

-  Names & telephone numbers of
-    persons with additional information
-    about the reported activity

- Summarize the report
-   & include:

## Important Reminder

**  **_**Do not**_** **include any supporting documentation or attachments to the SAR when filed

##    Financial institution shall retain for               5 years from the date of the filing:

- A copy of any SAR filed; ***and***
- The original or business record of ***any ***supporting documentation; ***and***
- Make all supporting documentation available to FinCEN & any appropriate                 law enforcement agencies or regulatory authorities

## Another Important Reminder

- 	Federal law requires that a financial institution, & its directors, officers, employees, and agents who, voluntarily or by means of a suspicious activity report, report suspected or known criminal violations or suspicious activity _may not_ notify any person involved in the transaction that the transaction has been reported.

## Questions?Call the FinCENRegulatory Help Line at 1-800-949-2732