Suspicious activity monitoring and reporting is the cornerstone of your BSA/AML program. Once you identify the suspicious activity, filling out the Suspicious Activity Report, and more specifically, the narrative, can be a little daunting. What’s the best way to articulate all the information you might have?
Listen to the video as Kevin explains what he believes to be the six most important items to get into you SAR narrative.
All About Suspicious Activity Monitoring and Reporting
Your suspicious activity monitoring and reporting is the cornerstone of your BSA program. Now, I know. When you sit down and you’ve gathered all of your information and you’ve determined that it’s time to file a SAR, oftentimes when you sit down at that keyboard and start typing in the suspicious activity report narrative, that can be the most daunting task of the entire process. How exactly are you going to articulate all of the information that you have in a format that’s easy to read? Now, I read a lot of suspicious activity reports and sometimes even very experienced BSA officers miss what I think are the six most important items to get into your narrative. It’s the who, what, where, when, why, and how of your narrative.
Who is conducting the suspicious activity? Now, I know that’s already been laid out in the rest of the SAR format, but sometimes in that narrative, you can get really confused as to who did what and who exactly are you focusing on? So who is conducting that suspicious activity? What instruments were used? Again, that is in the body of the SAR as well, but sometimes laying it out in that narrative and being very specific about what were the mechanisms or the instruments or what actually took place and what types of products or services at your banks were being utilized? When did the suspicious activity take place? That’s an easy one to miss simply because there’s a lot of dates already filled into the format.
But if you lay it out in the narrative, it helps investigators really understand what’s going on and piecing it together. Remember, they’re reading these very quickly, so sometimes just having it in that narrative can be really helpful.
- Where did the suspicious activity take place?
- Again, what is their branch information? Did the activity occur outside of the bank?
- Is there activity that occurred in different branches? Make sure you clarify that in the narrative. And then why does the filer think that this is suspicious?
In fact, that’s sometimes the most important part of the narrative that is easily missed. When you fill out all of the information, you have more information than the reader does, and sometimes it’s easy to forget.
You really have to lay out why you think it was suspicious. And then it’s also helpful to say, what crimes do you think might’ve been committed under these circumstances? Just laying that out in the narrative in an easy to understand format can be very helpful. And then finally, how did the suspicious activity occur? The final how. Laying all of that with a very clear and concise narrative can help law enforcement when they’re reading through these to really understand what you’re getting at. So keep in mind, you have the six most important things to make sure you get into your narrative, the who, what, where, why, and how. Thank you.
If you want to learn more be sure to check out our webinar, “All About Suspicious Activity Monitoring & Reporting”, which is available now, OnDemand.
Kevin brings years of experience and a unique perspective on regulatory matters to our clients. A self-proclaimed geek and accredited CRCM, Kevin is also a recovering attorney with experience as in-house counsel for a large regional bank and one of the leading national title insurance providers. For reasons unknown, Kevin decided to leave the safety and serenity of his desk job to seek fortune and glory as a wandering adventurer. Like a bank compliance version of Kwai Chang Caine, The Man with No Name or Don Quixote, he now travels the land seeking to help those in need and righting compliance wrongs, wherever he may find them.
Kevin lives in Sioux Falls with his two children, who are surprisingly normal after having endured their father’s vivid imagination for their entire lives. He won’t admit to having any hobbies, because apparently “Regulations never sleep.” (While he does say this in his Batman voice, we’re pretty sure he’s joking.) From the looks of his Facebook page, he likes the outdoors and spending time with his large extended family (who seem like relatively normal people).