SAR Narrations
By David Dickinson
During our recent BSA Seminars we heard from representatives from the IRS Criminal Investigation Division and the U.S. Attorney's Office about tips on how to complete the SAR Narrations. I also recently attended the Bankers Online BSA Conference and a representative of the IRS CID office repeated much of this information. All of these gentleman stated they wanted summaries without all of the details in the SAR narration. One even said to round off numbers to make easier for them to comprehend. The problem with this is the regulatory agencies require you to be specific and provide all of the details. Here's the solution: Give an executive summary in the first paragraph of the SAR narration. For instance:
"During a 4 week period, John Doe structured 7 cash transaction to evade a CTR. The highest amount a $9,800 and the lowest was $8,600 for a total of approximately $62,000."
Then you can give all of the details of the transactions, being specific on dates and amounts. Be sure to describe the who, what, when and where (as well as any other information you think might be helpful). During the BOL Conference, Tom Fleming (the Assistant Director of Compliance for FinCEN) was present and he indicated the details are important to them for in-depth studies of criminal activity. The only guidance we have indicates you must provide all of the details, but the users of this information (IRS, FBI, etc.) read hundreds or thousands of these every month. We need to provide a quick summary for them. Mr. Fleming indicated he would take this information back to D.C. and try to provide BSA guidance that indicates a quick summary followed by the details is a better approach to preparing SAR narrations.
Here's the bottom line: We're all fighting a war trying to get these criminals off of our streets. Let's give effective weapons (quick summaries) to the law enforcement agencies but give thorough details to meet the regulatory requirements and meet FinCEN's needs as well.