The conclusion section of a Suspicious Activity Report, or SAR narrative is where you wrap up your SAR. You summarize the reason for filing in this section, including the amounts and time period of suspected activity. Include any actions taken by the financial institution against the account as well as any law enforcement personnel to whom the SAR was reported, as well as a contact point for obtaining supporting documentation.
Other SAR filings unrelated to the suspicious activity, additional non-suspicious accounts held by the suspect, the history or profile of your financial institution, and any other observations you believe may be of interest can be included in this section.
Tips for Developing a SAR Narrative’s Conclusion
Knowing your audience, structuring a narrative in an easy-to-follow arrangement, and answering the five Ws and How are all best practice recommendations for writing a SAR narrative. Keeping these in mind when developing or revising your institution’s SAR processing procedures, providing a template to your designated SAR filer, or writing a SAR narrative yourself will help ensure your SAR narratives are easily understood.
Do not assume your reader is familiar with your organization’s internal jargon, acronyms, or processes. It can be difficult to recognize institution or industry terms that others may not be familiar with because you use them on a daily basis at work. To get around this, take a step back and concentrate on writing a SAR that the average consumer can understand. This ensures that plain language is used to effectively convey your intended meaning. The SAR narrative should be able to explain the chronology and observed suspicious behavior without using any acronyms or terms from your institution.
A SAR narrative should use the basic writing structure taught in school. This seems obvious, but it is often overlooked because industry writing lacks this structure. Instead of presenting a chronological story, shorter forms or bullet points are used to draw the reader’s attention to key terms or to facilitate discussion. There should be a beginning, middle, and end.
Begin with an introduction that states the reason for filing the SAR and provides a general description of the known or suspected violation. Then proceed to the body to answer the five Ws and How. Finish with a conclusion that summarizes the report and includes planned or completed follow-up actions, as well as names and contact information, if applicable.
It is critical that your institution submits complete SARs to Financial Crimes Enforcement Network, or FinCEN to ensure compliance. Writing a sufficiently detailed narrative is part of submitting a completed SAR. It is critical that your institution has policies, procedures, and processes in place to ensure that SAR narratives provide the necessary information on a consistent basis.
SARs help law enforcement detect and prevent criminal activity at the individual and systemic levels by identifying potential and actual illegal activity. Furthermore, it is required by law, so your financial institution must make a good faith effort to comply. The conclusion is crucial because it explains everything about the narrative and reminds the reader of what the narrative is all about.