THE SOURCE NEWSLETTER

Follow These 5 Rules to Spruce Up SAR Writing Skills

by Eli Research. Reproduced with permission.

In this article, Bill Goss, IPSA’s Director of AML Services, provides 5 suggestions to improve your staff’s SAR writing skills to create understandable and valuable SARs and leaving less room for error:

Think that regulators want to see you use highly-specific lingo? Think again.

If you aim to improve staff’s SAR writing skills, these five recommendations from former law enforcement officials will help you ramp up to clearer, more effective SARs in no time:

1. Do your homework.

Complete all of the research before you begin to draft a SAR, says William Goss, director of AML consulting services at IPSA International, Inc. in New York, who works with several former members of law enforcement. Too often, SARs contain outdated information — something that would have been evident if the person reporting had conducted adequate research.

Example: A compliance officer will file a report on an entity or person who no longer appears on any government watch lists. Takeaway: Don’t rely on your recollections of an account holder’s status — rather, go ahead and redo the background research if you suspect suspicious activity, notes Goss.

2. Leave the jargon out.

Avoid technical terms, product brand names or internal codes and abbreviations that an external SAR reader may not understand, relates Goss. Remember that the SAR you prepare may be reviewed by any one of ten law enforcement agencies.

Focus on writing clear and concise SARs and adequately explain any terms so that a college student would understand. If you take care to make yourself understood in the writing stage, you can avoid receiving a subpoena down the line because the SAR you wrote was indecipherable.

3. Aim for harmony.

While people naturally have different writing styles, aim for a consistent “voice” in your SAR narratives, recommends Goss. Make sure everyone in the organization hits on the five “W’s” (the who, what, why, when and where of suspicious activity).

Also, provide staff with examples of thorough SAR writing to emulate. Some larger banks separate the SAR investigator and writer roles, allowing each to focus on and specialize in her primary task.

4. Check and re-check for accuracy.

Make sure all of the information you entered is correct before you file a SAR, says Goss. Many of the SARs his firm reviews contain errors in transactions numbers, date ranges, dollar amounts and the like, he shares.

5. Don’t forget the post-filing follow-up.

Remember that your duty is not complete until you have assessed any underlying risk in the account that generated the SAR. You may have to file supplemental SARs or close the account if you find additional evidence of suspicious activity, Goss notes.

Resources:

Use the following publications as a reference guide, particularly for new SAR writers

• Keys To A Well-Prepared Suspicious Activity Report.
  This is a 20-slide PowerPoint presentation that clearly and simply lays out the framework for preparing and writing a SAR. The document outlines the principle of the five “W’s” and includes FinCEN’s contact number, 1-800-949-2732.
• Guidance On Preparing A Complete And Sufficient Suspicious Activity Report Narrative.
  This document contains very detailed guidance and examples to help with the SAR section that seems to confuse or intimidate many new SAR writers: the narrative. (Look on page 46 for helpful examples drawn from this publication.)
• The SAR Activity Review, Trends, Tips and Issues.
  FinCEN published issue 13 in May. Each edition contains interesting statistics about SARs FinCEN received and, as the title indicates, useful trends and tips for the SAR writer.
• The Federal Financial Institutions Examination Council (FFIEC) BSA/AML Examination Manual.
  While the four-hundred page document appears daunting, start by focusing on the SAR overview and Appendix L on SAR quality.

Sum up:

Do your homework, use available internet resources and follow common sense rules to steer down the path to useful SARs.

Back to Top