Insight Article • What specifically led to the SAR? Describe the transactions, what instruments were involved, and the activities that raised suspicions. • When did the activity occur? If this was a one-time incident, identify the date of the occurrence. If there was continued activity or a pattern of behavior, state the span of time and when the activity first originated, when the activity was detected, and a description of the activity during the duration. This is important to assist your reader in connecting the dots. • Where did the activity take place? Here you should state the branch, department, and location(s) where the activity occurred and street address(es). • Why is the activity suspicious? This is where persuasive language is useful. Write as if you are looking to convince a skeptical audience (you are).

Identify accounts and account types affected. Describe why the activity is suspicious and any relevant information kept in your file documentation. • How did the activity occur? Describe how the suspect’s transactions or pattern was completed. Narratives for Continuing Activity SARs When completing the narrative section of a SAR filed for continuing activity, be sure to identify the date of any SAR previously filed on the subject and the purpose of that SAR. Where continuing activity occurs, a SAR must be filed after a 90-day review.

The filing deadline is 120 days after the filing date of the previously related SAR, although the continuing activity SAR may be filed earlier than the deadline should your financial institution believe the activity warrants earlier review by law enforcement. Conclusion SARs work to identify potential and actual illegal activity and provide law enforcement a means to detect and prevent criminal activity at the individual and systemic level. In addition, it’s required by law, making it vital that your financial institution make a good faith effort to comply. To ensure compliance, it is imperative that your institution submit to FinCEN SARs that are complete.

Part of filing a completed SAR includes writing a sufficiently comprehensive narrative. It is important that your institution have the policies, procedures, and © Wipfli LLP processes in place to ensure SAR narratives consistently provide the necessary information. Additional Resources • FFIEC BSA/AML Examination Manual Appendix L: SAR Quality Guidance • FinCEN SAR FAQ • March 2015 the FinCEN SAR Electronic Filing Requirements • FinCEN SAR Stats Technical Bulletin October 2015 • FinCEN SAR Narrative Spotlight July 2015 About the Author Nick Bonnema is a results-oriented banking professional with six years of financial institution experience, specializing in regulatory compliance audits, BSA/AML/OFAC consulting, and the mitigation of regulatory risk. Nick works with financial institutions to address the overall administration of compliance directives, review and make compliance policy and procedure recommendations, and help senior management implement recommendations to meet the changing expectations of the financial services industry.

Nick’s communication and research skills allow him to understand a client’s specific needs, and then use this knowledge to develop and deliver customized, sensible solutions. Nick has a Juris Doctor from the William Mitchell College of Law. He can be reached at nbonnema@wipfli.com. About Wipfli LLP The mission of Wipfli’s Financial Institutions Practice is to educate, advise, and assist financial institutions in successfully navigating the complex environment they face.

Our clients range from small community financial institutions to multi-billion dollar organizations. The practice consists of certified internal auditors, certified compliance specialists, former financial institution personnel, former regulators, and licensed certified public accountants regionally recognized for their knowledge and expertise. Whether your needs include regulatory compliance, profit improvement, risk management, strategic planning/board development, information technology, audit, or tax, let our experts assist you. For more information, visit www.wipfli.com. 2 .