In the recent SAR Activity Review
, sections are provided that outline the basic aspects toward filing a SAR. In particular, the section on writing an effective SAR Narrative is important to consider.
FinCEN rightly states that the narrative "is a critical part of the SAR because it is where the filer can summarize and provide a more detailed description of the activity being reported." For that reason, it is essential that the narrative be clear, complete and thorough.
This section of the FinCEN report offers the "5 W's" that I have written about extensively as a way to develop the SAR narrative.
(See, for instance, my magazine article, Anti-Money Laundering Program - Preparation is Protection
, August 2012.)
Our clients have learned how to use this narrative method.
The FinCEN report does not mention the "How" narrative that I have advocated - and which I will discuss below.
In my view, the Anti-Money Laundering Program should have an appendix devoted exclusively to the SAR Narrative procedures, especially outlining the "5 W's and the How" method of writing it.
The narrative must be clear, complete and thorough and the method I advocate is an effective means toward accomplishing these goals.
FinCEN's outline is rather brief, so I will provide a much more extensive set of action steps for you to follow.
The article contains the "5 W's"
method provided by FinCEN, after which I will add some remarks about narrating the "How".
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