Suspicious Activity Report (SAR) Filing

Collect all evidence related to the suspicious activity. This includes transaction records, account statements, identification documents, notes from staff who observed the activity, and any prior alerts on the subject. Document the who, what, when, where, why, and how: - Who is 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)

Write a clear, factual narrative describing the suspicious activity. This is the most important part of the SAR. Examiners and law enforcement rely on it. Good narratives: - Tell the complete story in plain language - Include specific dates, amounts, and account numbers - Explain why the activity is suspicious - Reference any relevant patterns or prior SARs - Avoid speculation - stick to facts Per FinCEN guidance, the narrative should enable law enforcement to understand the activity without reviewing attachments.

The BSA Officer reviews the complete SAR package for accuracy, completeness, and appropriate classification. Verify the narrative clearly explains the suspicious nature of the activity. Review checklist: - All required fields completed - Narrative is clear and comprehensive - Subject information is accurate - Suspicious activity is clearly articulated - Supporting documentation is referenced Return for revision if anything is unclear or incomplete.

Submit the SAR through FinCEN's BSA E-Filing System. You have 30 calendar days from when activity was detected to file (35 days if subject was unknown at detection). Retain a copy of the filed SAR and confirmation for 5 years. Filing reminders: - Keep SAR confidential (31 USC 5318(g)(2)) - Never tip off the subject - Document the filing date and confirmation number - Set retention calendar for 5 years minimum Per 31 CFR 1020.320, maintain SAR confidentiality - disclosure is a federal offense.