The heart of the suspicious activity report (SAR) lies in the five Ws.
Jenna North, training team lead with Verafin, outlined the five Ws during a session at the 2018 CUNA Bank Secrecy Act Certification Conference with NASCUS Wednesday in Louisville, Ky.
The Ws are:
► Who. The “who” identifies any suspects and their relationship with the credit union. This includes the suspect’s occupation, identification, any addresses, and a full description of the relationship. “This is where you make those connections, maybe identify a crime ring, and stop that activity,” North says.
Occupation and the nature of the business is also a critical part. “A convenience store clerk is not going to earn $85,000 a year,” North says. Likewise, the validity of address and identification are critical.
► What. The what is the key part of the SAR, North says, because this is where the “full picture” of the event is developed. “This is taking all that information you have in your head and all of the information you’ve gathered and transcribing it, writing it down,” she says.
This information includes:
► When. This includes not only how long the activity has been taking place but also how long the investigation has been ongoing. “Law enforcement needs to know if the activity is still taking place,” North says. Transaction dates and amounts should also be included.
► Where. For credit unions, this is often the branch where the incident occurred. It may also include any domestic and foreign jurisdictions and account numbers
► Why. This is the industry and location, North says. It also includes any unusual and suspicious activity.
In writing the narrative, North says it’s important to tell what caused the suspicion and tell the story chronologically. All transactions should be included—both attempted and completed—and should include beneficiaries of transactions. Also include any supporting documentation.
The SAR writer should list any litigation. Include victims only if they’re needed to tell the narrative. “Only put the victim in the narrative if you need them to tell the story,” North says.
Keep the narrative concise and repeat information only where necessary, North says.