The narrative section in the Suspicious Activity Report (SAR) is the only free text area for describing the suspicious activity, making it the most vital portion of SAR. The purpose of the narrative part of SAR is to provide a clear and concise understanding of the suspicious activity and the reason for filing SAR.
The narrative should essentially answer the five ‘W’s:
- Who: Description of the client conducting the suspicious activity and other people involved in the suspicious transactions, including any incriminating information about the transactors.
- What: Identify the instruments or mechanisms used to facilitate criminal activity.
- When: Provide the timeline of the suspicious transactions.
- Where: Identify the location of transactions that the institution suspects violate the law.
- Why: Explain the reason for suspecting the transactions or the irregularity in the transactions.
The most poorly written narrative simply says ‘see attached files’ so avoid this mistake. Instead, the narrative should elaborate on the information provided in the preceding SAR data fields. A compelling narrative requires quick data capture, thorough research, and analysis of the data. Your institution can use tools like ScanWriter by Personable Inc for automated data capture, analysis, verification and investigation through assistance of financial models to allow you to write a productive narrative.
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Now, let’s look at how to structure your narrative.
A compelling and sufficient narrative has three main sections that the institution should elaborate on to allow the investigation agency to investigate effectively. Inaccurate or incomplete SAR will make it challenging to analyze the available information properly.
Structure of SAR Narrative
The narrative section allows the institution to summarize the suspicious activity in 20,000 characters. Do not file another SAR on the same suspicious activity to accommodate narratives longer than the SAR narrative’s character limits, resulting in duplication. The institution can attach an additional note if the character limit is insufficient at the end of the online SAR and any necessary documents.
Give a gist of the suspicious activity and the reason for filing SAR. Also, provide a brief description of the client and any prior antecedents against the client or persons involved in suspicious transactions. The introduction is basically to set the stage for the body of the narrative consisting of all the relevant information.
Use the body of the narrative to give all the relevant facts related to the client and the suspicious transactions. Explain how the transactions are different from the regular pattern and what kind of criminal activity might be undertaken by the client. It is essential to elaborate on when and where the client and the transactors entered into the suspicious transactions. In addition, the institution should also mention the instruments used to undertake the suspicious activity. Further, explain the results of any internal investigation and research conducted by the institution. Also, provide all the information about the transactors and their relationship with the client. Additionally, explaining the client’s occupation can also help in identifying the irregularities in transactions. Finally, if traceable, the institution should include information about the flow of funds, source, use, destination, or ultimate beneficiary of funds.
Use the last few paragraphs to summarize and explain the reason for filing SAR. Also, provide the details of any attachments included. Finally, give the details of the official who will act as the point of contact in case it is different from the one provided in the preceding sections of online SAR.
Example Considered Sufficient
S has been a client of ABC bank for the last 15 years. Due to the nature of S’s business, ABC monitors the account of S as it is under its high-risk category of clients. As a result, ABC is filing the present SAR since it has recently identified some unusual financial transactions in S’s account. The suspected activity seems to be facilitating tax evasion for an entity called XYZ Corporation.
A review of activity on the ABC Bank account no. 000012345 in S’s name indicates that recent activity is inconsistent with regular transactions. Upon inquiry, ABC Bank has not located any previous SARs within its records related to S. Transactions spanning 11/17/2018 to 08/31/2019 were reviewed and showed five deposits totaling $3,601,300.
The first transaction was a wire transfer of $1,000,000 on 11/17/2018.
The second transaction was a cash deposit of $500,000 on 01/03/2019.
The third transaction was also a cash deposit of $351,300 on 02/28/2019.
The fourth translation was another wire transfer of $1,000,000 on 05/19.2019.
The fifth transaction was a cash deposit of $ 750,000 on 08/31/2019.
Two transactions of $1,000,000 each in wire transfers have come from XYZ Corporation. Additionally, the location of cash deposits of $1,601,300 is detected to be the British Virgin Islands.
These transactions are irregular as in the last 15 years of operation of its account, S has never transacted such massive amounts. Moreover, S is in the business of masonry and carpentry, which is cash intensive; thus, S never has transactions of such large sums.
According to ABC’s internet research, XYZ was named in one of the global scams in 2015 and is an apparent shell off-shore company set up in the British Virgin Islands. Also, upon inquiry, S has stated that the said transactions were business transactions for carpentry work done for his client, which the Bank finds doubtful. Furthermore, there is no explanatory note or message in the narration for the transactions, such as invoice numbers or other references for the purpose stated by S.
The wire activity and cash deposits do not make business sense. Therefore, the institution is filing this SAR to indicate the suspicious activity detailed above for further investigation by the law enforcement agency. XYZ is the subject of prior investigation and does not seem to carry any business operations at all. Such a massive amount of transactions in the account of S from a non-operative entity makes it highly suspicious and irregular. The Bank suspects that XYZ is trying to evade tax with the help of S in such transactions.
The Bank is providing the complete transaction details and record regarding XYZ in the attachments to the SAR. Supporting documentation is available upon request. For further information, the Bank has provided the contact details of the concerned official at the Bank in the relevant section of SAR.
Example Considered Insufficient
ABC Bank is filing SAR against S. A review of the account activity of S in the last two years has revealed some suspicious activity. The transactions amount to approximately Three Million USD. These transactions include a couple of wire transfers from XYZ Corporation, with whom S has never transacted before. When asked, S informed the Bank that the said transactions were for the carpentry services provided to XYZ. The cash deposit amounts are large and irregular in S’s account as per previous activity.
For details on transactions, see the attached account statement of S.
Millions of SARs are received by the Financial Crimes Enforcement Network (FinCEN) every year. It is challenging for FinCEN to sift through these SARs to identify which SARs it needs to send to law enforcement agencies for investigation. The purpose of the SAR narrative is to identify suspicious activity and simplify the job of the law enforcement agencies. However, insufficient or incomplete narratives in SAR end up burdening the law enforcement agencies, making it nearly impossible to handle the SARs with the attention they deserve.
The examples above give an insight into a sufficient narrative to help the investigating agency identify and investigate the suspicious activity. The information in example one already provides enough leads to the investigation agency for productive analysis and investigation. Therefore, the institutions need to file SARs with complete narratives to help identify criminal activity proactively. It should not be solely a procedural formality in compliance with BSA regulations.