Who Is Reading Your SAR And Why? Writing With Purpose

Author: Terri Luttrell, CAMS-Audit

In the real world of an AML professional, a SAR narrative must be written to a different audience, such as FinCEN and the institution’s state (when applicable) and federal regulators. Regardless of what the intentions of a BSA officer are for fulfilling the requests of law enforcement when approving SAR narratives, the facts remain that they must meet all regulatory requirements with no exceptions. This is not only what puts a BSA officer’s job on the line, but it also puts the institution at risk. Is it possible to soar through a regulatory exam while assisting law enforcement with the most important part of an AML professional’s job—stopping the bad actors? That question will be pursued as the guidance presently offered on this topic is analyzed in order to determine if a conclusion can be determined that satisfies all of the audiences while meeting regulatory expectations.

Download PDF