File SARs that meet FinCEN requirements

Pull together all the evidence tied to the suspicious activity. You'll need transaction records, account statements, ID documents, staff notes from anyone who witnessed the activity, and any prior alerts on the subject. For each piece of evidence, make sure you're covering the full picture: - Who's involved (subjects, accounts, third parties) - What happened (specific transactions or behaviors) - When it occurred (dates, times, frequency) - Where it happened (branch, online, ATM) - Why it's suspicious (what makes it unusual) - How it was conducted (methods, patterns) Don't wait until the last minute - gaps in documentation are one of the most common reasons a SAR gets kicked back for revision.

Write a clear, factual narrative that describes the suspicious activity. This is the most important part of your SAR - examiners and law enforcement will rely on it, so don't rush it. A good narrative: - Tells the complete story in plain language - Includes specific dates, amounts, and account numbers - Explains why the activity is suspicious - References any relevant patterns or prior SARs - Sticks to facts - don't speculate Per FinCEN guidance, your narrative should let law enforcement understand the activity without needing to pull attachments. If it's not clear in the narrative, it's not clear.

As the BSA Officer, you're reviewing the complete SAR package for accuracy, completeness, and correct classification. Check that the narrative clearly explains why the activity is suspicious - if you can't tell from reading it, law enforcement won't be able to either. Your review checklist: - All required fields are filled in - The narrative is clear and covers the full picture - Subject information is accurate - The suspicious activity is spelled out plainly - Supporting documentation is referenced If anything is unclear or incomplete, send it back for revision. Don't approve a SAR you're not confident in - accuracy matters here, and errors can undermine law enforcement investigations.

Submit the SAR through FinCEN's BSA E-Filing System. You've got 30 calendar days from when the activity was detected to file (35 days if the subject wasn't identified at the time). Missing this deadline isn't an option - it's a regulatory violation. Once filed: - Keep the SAR confidential (31 USC 5318(g)(2)) - disclosing it is a federal offense - Never tip off the subject that a SAR was filed - Record the filing date and confirmation number immediately - Set a retention reminder: you're required to keep the SAR for at least 5 years Per 31 CFR 1020.320, SAR confidentiality isn't just best practice - it's the law. Treat these records accordingly.