Speaker 1: Did you know writing an effective SAR, particularly the SAR narrative, is an art form? The details in the narrative assist law enforcement agencies with investigating money laundering, terrorist financing, and financial crimes investigations. The good news? There are some tips that you can use to write a valuable narrative. First and foremost, be timely and accurate. Base the information in your SAR on facts. Keep it clear, concise, and accurate. Keep in mind the reader isn't familiar with your institution's operational process, acronyms, or terminology. Now, let's go back to your old grade school English class where your essay needed to include the who, what, where, when, why, and how. Your SAR narrative should include the same. The who. Who is conducting the criminal or suspicious activity? Where do they live? Where do they work? How long have they been a customer or member? This should include additional details not provided earlier in the SAR form. The what. What instruments or mechanisms were used to facilitate the suspect activity? Make sure to identify and describe the transactions raising suspicion. Were there cash deposits or withdrawals? Were monetary instruments used such as money orders, cashier's checks, or institution checks? Were digital currency or gift cards used? How about wires, ACH transactions, or share drafts? Or foreign currency, casino chips, stocks, or bonds? The where. Where did the suspicious activity occur? Were there multiple branches, departments, or ATMs involved? Were other financial institutions involved? How about foreign jurisdictions? You'll want to identify all departments and locations involved, as well as where they're located, including their name and street address. Be sure to include all account types and account numbers involved as well. The when. When did the suspicious activity occur? Did it only happen once? Was there a pattern of activity over a particular time period? Be sure to identify the specific date or dates the activity occurred, as well as when the activity was detected. Don't forget, you are required to file your SAR within 30 days of detecting suspicious activity. The why. Why does your organization believe the activity is suspicious? Are the transactions unusual for your institution? Are the transactions out of pattern for this particular account holder? Include any relevant information about suspicious account holder activity that you may have in your files at the time you filed the SAR. The how. Lastly, how did it occur? How was the suspect transaction or transactions completed? Provide as much detail as possible about the cycle of funds, including the source of the funds in the account and how they were applied. FinCEN recommends you format your narrative in three parts. Part 1, Introduction. Your introduction should provide a brief statement of the SAR's purpose, generally describe the issue, acknowledge dates of any SARs filled previously on the same issue, and include any internal investigative identification used by your institution to maintain records of the SAR. Part 2, Body. The meat of your narrative is in the body, which is where you provide all the relevant facts about the suspect activity. This is where you answer who, what, where, when, why, and how. Part 3, Conclusion. Finally, you summarize your report and include any planned or completed follow-up actions, as well as contact information of individuals with additional information about the suspect activity. You should also mention where all SAR-related records are maintained within your organization. A few cautions and reminders. Do not use or insert tabular objects, tables, or pre-formatted spreadsheets into your SAR. Do not include any supporting documentation or attachments to the SAR when you file it. You may not notify any person involved in the suspicious activity that the SAR has been filed. You must retain a copy of the SAR and any supporting documentation for five years from the filing date. The information provided in a SAR is used by law enforcement as pieces to a bigger puzzle. Complete and accurate information is a must. The FinCEN website has a three-part guidance package to help financial institutions prepare suspicious activity report forms and improve the quality of their SAR narratives. Visit the link in the video's description below to download the package. For more information about filing a SAR or your reporting responsibilities, don't hesitate to reach out to our member support team at 800-500-0100, memserv at epcor.org, or via chat on epcor.org.