Page 21 - ACAMS-Today-V20N3

[ AML CHALLENGES ]
Law enforcement reports that they frequently receive SARs with narratives that are confusing, inconsistent, poorly written and/or give no clear indication of the dollar amount and the nature of the criminal activity
Step 1
Complete all fields accurately and completely.
Step 2
Develop a standard format for all SAR narratives such as:
• Introductory paragraph
• Background paragraph
• Transaction section7
• Summary8
• Section on next steps
• Supporting documentation that is available
Step 3
Understand that a paragraph is a subdivision of a written composition that consists of one or more sentences and deals with one point or gives the words of one speaker. Paragraphs usually consist of three to five sentences.
Step 4
Make sure the first paragraph is only three to five sentences long and that it includes the following:
• The reason the SAR is being filed along with the red flags or potential scheme
• The names of all subjects (who committed the suspicious activity, not the victim)
• The dollar amount of this SAR (include the total amount of all SARs if it is a continuing SAR)
• A brief explanation of the transactions involved
• The relationship between subjects and how they were found (such as external research)
Step 5
Include the following in the other sections of the narrative:
• Background: Subjects, ID, account
——Yes, some of this is listed in the other sections of the SAR, but still put it here as well.
• Transaction summary: The beef of the SAR
——Make it a summary, as lists of transactions are best put in an attachment.
• Conclusion: Bring all the points together ——State what you think is the criminal activity.
• Section on the next steps: What do you plan to do going forward? ——Close the account, monitor the activity, etc.
• Supporting documentation: List everything that was covered in the investigation. Let law enforcement know what they can get without a subpoena. This includes, but is not limited to, the following:
—— Customer due diligence (CDD) review: All accounts reviewed even if no suspicious
activity was found.
——External research: Website searches, negative news ——314(a) matches and 314(b) communication
——List of transactions with dates, times, days of the week ——IP addresses
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