GUIDE

A to Z Guide
to Preparing
Narrative for
Suspicious
Activity
Report
Learn how to provide a clear and
concise understanding of the
suspicious activity.

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GUIDE
SUSPICIOUS ACTIVITY REPORT
The narrative section in the Suspicious Activity Report (SAR) is the
only free text area for describing the suspicious activity, making it the
most vital portion of SAR. The purpose of the narrative part of SAR is
to provide a clear and concise understanding of the suspicious activity
and the reason for filing SAR.

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The narrative should essentially answer the five ‘W’s:

Description of the client conducting the

suspicious activity and other people

Who involved in the suspicious transactions,

including any incriminating information
about the transactors.

Identify the instruments or mechanisms

used to facilitate criminal activity. What
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When
Provide the timeline of the suspicious
transactions.

Where
Identify the location of transactions
that the institution suspects violate
the law.

Why
Explain
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the reason for suspecting the
transactions or the irregularity in the
transactions.

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The most poorly written narrative simply says
‘see attached files’ so avoid
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this mistake. Instead,
the narrative should elaborate on the information
provided in the preceding SAR data fields. A
compelling narrative requires quick data capture,
thorough research, and analysis of the data. Your
institution can use tools like ScanWriter by
Personable Inc for automated data capture,
analysis, verification
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and investigation through
assistance of financial models to allow you to
write a productive narrative.

Now, let’s look at how to structure your narrative.

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A compelling and sufficient narrative has three
main sections that the institution should
elaborate on to allow the investigation agency to
investigate effectively. Inaccurate or incomplete
SAR will make it challenging to analyze the
available information properly.

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Structure of SAR Narrative
The narrative section
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allows the institution
to summarize the suspicious activity in
20,000 characters. Do not file another
SAR on the same suspicious activity to
accommodate narratives longer than the
SAR narrative’s character limits, resulting
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in duplication. The institution can attach
an additional note if the character limit is
insufficient at the end of the online SAR
and any necessary documents.

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Introduction
Give a gist of the suspicious activity and the reason for filing SAR. Also,
provide a brief description of the client and any prior antecedents against the
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client or persons involved in suspicious transactions. The introduction is

basically to set the stage for the body of the narrative consisting of all the
relevant information.

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Body
Use the body of the narrative to give all the relevant facts related to the
client and the suspicious transactions. Explain how the transactions are
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different from the regular pattern and what kind of criminal activity might be
undertaken by the client. It is essential to elaborate on when and where the
client and the transactors entered into the suspicious transactions. In
addition, the institution should also mention the instruments used to
undertake the suspicious activity. Further, explain the results of any internal
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investigation and research conducted by the institution.

Also, provide all the information about the transactors and their relationship
with the client. Additionally, explaining the client’s occupation can also help in
identifying the irregularities in transactions. Finally, if traceable, the institution
should include information about the flow of funds, source, use, destination,
or ultimate beneficiary of funds.

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Conclusion
Use the last few paragraphs to summarize and explain the reason for filing
SAR. Also, provide the details of any attachments included. Finally, give the
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details of the official who will act as the point of contact in case it is different
from the one provided in the preceding sections of online SAR.

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Example Considered Sufficient
S has been a client of ABC bank for the last 15 years. Due to the nature of S’s
business, ABC monitors the account of S as it is under its high-risk category
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of clients. As a result, ABC is filing the present SAR since it has recently
identified some unusual financial transactions in S’s account. The suspected
activity seems to be facilitating tax evasion for an entity called XYZ
Corporation.

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A review of activity on the ABC Bank account no. 000012345 in S’s name
indicates that recent activity is inconsistent with regular transactions. Upon
inquiry, ABC Bank has not located any previous SARs within its records
related to S. Transactions spanning 11/17/2018 to 08/31/2019 were reviewed
and showed five deposits totaling $3,601,300.

The first transaction was a wire transfer of $1,000,000 on 11/17/2018.

The second transaction was a cash deposit of $500,000 on 01/03/2019.

The third transaction was also a cash deposit of $351,300 on 02/28/2019.

The fourth translation was another wire transfer of $1,000,000 on

05/19.2019.

The fifth transaction was a cash deposit of $ 750,000 on 08/31/2019.

Two transactions of $1,000,000 each in wire transfers

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Corporation. Additionally, the location of cash deposits of $1,601,300 is
detected to be the British Virgin Islands.

These transactions are irregular as in the last 15 years of operation of its

account, S has never transacted such massive amounts. Moreover, S is in the
business of masonry and carpentry, which is cash intensive; thus, S never has
transactions of such large sums.

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According to ABC’s internet research, XYZ was named in
one of the global scams in 2015 and is an apparent shell
off-shore company set up in the British Virgin Islands.
Also, upon inquiry, 7S has stated that the said transactions
were business transactions for carpentry work done for
his client, which the Bank finds doubtful. Furthermore,
there is no explanatory note or message in the narration
for the transactions, such as invoice numbers or other
references
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for the purpose stated by S.

The wire activity and cash deposits do not make

business sense. Therefore, the institution is filing this
SAR to indicate the suspicious activity detailed above for
further investigation by the law enforcement agency.
XYZ is the subject of prior investigation and does not
seem to carry any business operations at all. Such a
massive amount of transactions in the account of S from
a non-operative entity makes it highly suspicious and
irregular. The Bank suspects that XYZ is trying to evade
tax with the help of S in such transactions.

The Bank is providing the complete transaction details

and record regarding XYZ in the attachments to the
SAR. Supporting documentation is available upon
request. For further information, the Bank has provided
the contact details of the concerned official at the Bank
in the relevant section of SAR. 9

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5
Example Considered Insufficient
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ABC Bank is filing SAR against S. A review of
the account activity of S in the last two years
has revealed some suspicious activity. The
transactions amount to approximately Three
Million USD. These transactions include a
couple
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of wire transfers from XYZ
Corporation, with whom S has never
transacted before. When asked, S informed
the Bank that the said transactions were for
the carpentry services provided to XYZ. The
cash deposit amounts are large and irregular
in S’s account as per previous activity.

For details on transactions, see the attached

account statement of S.

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Wrap Up
Millions of SARs are received by the Financial Crimes Enforcement
Network (FinCEN) every year. It is challenging for FinCEN to sift through
these SARs to identify which SARs it needs to send to law enforcement
agencies for investigation. The purpose of the SAR narrative is to identify
suspicious activity and simplify the job of the law enforcement agencies.
However, insufficient or incomplete narratives in SAR end up burdening the
law enforcement agencies, making it nearly impossible to handle the SARs
with the attention they deserve.

The examples above give an insight into a sufficient narrative to help the
investigating agency identify and investigate the suspicious activity. The
information in example one already provides enough leads to the
investigation agency for productive analysis and investigation. Therefore, the
institutions need to file SARs with complete narratives to help identify
criminal activity proactively. It should not be solely a procedural formality in
compliance with BSA regulations.

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