SAR Tips
By Amy Kudlacek
I sat through a very interesting presentation last Friday at our local Compliance Professionals meeting. Special Agent Derick Tarr from the IRS Criminal Investigation Division (CID) spoke to the group about Suspicious Activity Reports (SARs). While his talk focused primarily on SARs filed in Nebraska, he did have some helpful advice for all persons responsible for the filing of SARs.
Special Agent Tarr's office consists of nine agents to oversee the entire state of Nebraska. That's not a lot of personnel for the amount of work that needs to get done on daily basis. Bankers often express frustration about filing SARs because they feel that they are doing a lot of work for very little gain. They don't believe the SARs they file are getting the attention they deserve. Special Agent Tarr indicated that he and his review team personally look at every single SAR filed in the State on a monthly basis. That is approximately 200 a month for just Banks and other Financial Service Businesses. This number does not include the SARs filed by Money Service Businesses or Securities and Futures Businesses.
Special Agent Tarr was quick to point out that not all SARs receive the same amount of attention. Most of the review is based on the reviewer's memory. They are looking for familiar names, dates, associations, etc. When the review team is looking at so many SARs per month, the time spent on the initial read of the SAR can be very short. Since the time is so limited, Special Agent Tarr passed along some helpful tips to give your SAR more substance and to get the reviewers attention.
- First, state why you are filing the SAR in the first couple sentences. When a reviewer is looking at so many SARs in a day, they may lose interest in long drawn out explanations. The best way to start your SAR narrative would be "This SAR is being filed because the bank suspects check kiting".
- Second, don't get caught up in providing a laundry list of amounts and dates in the narrative. You can simply state "Suspected checks kited from January 1, 2008 to March 31, 2008 totaled $55,238.15". NOTE: You should keep the more detailed listing as supporting documentation.
- Third, if the SAR you are filing is the second or third you have filed on the person or activity, state that in the narrative. If the agents know that there is continuing activity, they are more likely to take a closer look.
The most important thing is to not get frustrated. Bankers are making a difference in detecting and preventing financial crimes and money laundering. These Special Agents cannot effectively do their job if the SARs are not coming into their office. I encourage you to contact your local IRS CID and get to know them.