Part V (Suspicious Activity Information – Narrative) of the Suspicious Activity Report (SAR) is the most important section. While it’s essential that you report complete and accurate information about the suspicious activity in the other sections of the SAR, the Narrative is the meat. It’s where you explain the nature and circumstances of the activity and why it’s unusual. It’s where you tell the story. FinCEN states that an accurate and complete SAR narrative should identify the five essential elements - who? what? when? where? and why? - of the suspicious activity being reported…otherwise, the information contained in the SAR is of limited utility. FinCEN also requires that any supporting documentation be described in the Narrative.
Kevin took a deep dive into the SAR Narrative during the AML/CFT Membership Group. He also shared some best practices to help you write a Narrative that will be the most effective to assist FinCEN and law enforcement in their efforts.
Published
2025/06/18