6 Steps on How to Write a Suspicious Activity Report Narrative

6 Steps on How to Write a Suspicious Activity Report Narrative
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October 27, 2021

Resource: Blog Industry: Casino
Tags: Anti-Money Laundering (AML), Online Training, Staff Training

The highly stimulating environments of casinos and gaming organizations are bustling with excitement and swarming with activity. Sometimes all of that exhilaration and commotion can serve as the perfect disguise for the wrong kind of activity, like money laundering or even terrorist financing schemes. Having a solid Banking Secrecy Act (BSA) program in place can be the tipping point for protecting your business and aiding regulatory agencies in successful investigations against financial crimes.

The key to having a strong BSA program is knowing how to write a Suspicious Activity Report (SAR) narrative well. FinCEN uses this data to track important threats and trends to provide guidance for regulatory agencies and law enforcement. Compliance culture casinos that submit SARs promptly and accurately are instrumental to law enforcement investigations. Unfortunately, if not done correctly, such as lacking proper details or filing incomplete forms, SARs can hinder rather than help ongoing investigations, or make launching one difficult.

Because reporting suspicious activity to FinCEN is not only helpful, but required by law for financial institutions, like casinos, it’s imperative to know how to write a SAR narrative that is concise yet thorough while both timely and fully completed. An easy approach to this is being mindful of the five Ws: Who, What, When, Where, Why… and How.

6 Steps on How to Write a Suspicious Activity Report Narrative

  1. Who conducted the activity? In addition to following Part One guidelines of the report, the narrative is an opportunity to go into more detail that may not have been covered previously, including explaining the suspects’ occupation information, the relationship between them and your property as well as the length of time for that relationship.
  2. What happened to raise suspicion? What was the transaction? Describe the behavior or action that alerted you to suspect “bad acting” along with tools or instruments (gift card, cash deposits/withdrawals, money orders) used to conduct the activity. 
  3. When did the suspicious activity occur? This includes frequency—only once or over a period of time—as well as dates, duration, timelines, and indicating the first time the occurrence took place, if more than once.
  4. Where did it take place? Be as specific as possible, listing the property, area, landmarks, a street address, or any other information you have that pinpoints the location.
  5. Why is it considered suspicious? Tell the truth, but be explicit as possible with what made this activity or transaction abnormal or alarming. Regulatory officers receive hundreds of reports, so make it easy for them to understand this unusual occurrence being described and conclude that it is, in fact, suspicious activity.
  6. How did it happen? Here’s where you can bring it all together and sum up how the suspicious behavior or activity played out. The five Ws are most important, but the "how" can serve as the recap or summary.

A few final tips to note are keeping in mind who you’re sending the report to and anticipate the details that are most important to them; make writing a successful narrative replicable by establishing a template or guideline, like this one, for everyone to follow, especially if you don’t have a designated SAR filer; and use simple language instead of jargon or terminology specific to your property or gaming organization that might be confusing to others. Writing can be intimidating for some, using the 6 steps above will improve your accuracy and overall writing for the SAR narrative. Lastly, remember to complete the entire report, keeping the narrative concise, clear, and thorough.

For FinCen’s SAR Narrative Guidance Package, which has three parts, click here or below:

Want a closer look at Vector Solutions Casinos’ courses on Title 31 SAR Incident Scenarios and Reporting or SAR Incident Reporting for IT, along with dozens of other topics from HR to compliance to leadership? Request our Course Catalog here.

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About Vector Solutions

Vector Solutions for Casinos has been in the industry for over 10 years, as the leading Saas provider for online Title 31 and Anti-Money laundering training, helping clients meet federal mandates for reporting certain currency transactions to uncover money laundering and other financial crimes. Over the years we have built a comprehensive gaming-specific course catalog containing nearly 150 online training courses from Customer Loyalty, to Safety, Leadership Training and more, all hosted in our powerful Learning Management system, Vector LMS (formerly CELEXA, a Casino Essentials brand).

We proudly serve over 350 casinos nationwide. Vector LMS for Casinos is trusted by Boyd Gaming, Jack Entertainment, Bally’s Corporation, Four Winds Casinos, Wind Creek Hospitality, Desert Diamond Casinos, Muscogee Creek Nation Casinos, Delaware North Casinos, & Foxwoods Resort Casino and more! Our learning management system, Vector LMS for Casinos, is the most user-friendly platform on the market.

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