ACAMS Today Magazine (Nov-Dec 2008) Vol. 7 No. 6 | Page 32

PRACTICAL SOLUTIONS SARs: A template for success A nti-money laundering (AML) officers are increasingly utilizing templates to draft Suspicious Activity Reports (SARs) as a way to drive efficiencies, enable a consistent writing style among investigators and address deficiencies in AML programs. But to reap the full benefits templates can provide and to prevent unintended negative impacts, financial institutions need to first consider several factors around the people and processes involved in template creation, usage and management. Not all templates are created equal The definition of a template varies among financial institutions. While some templates, for example, address the entire SAR form, others only focus on the narrative section of the report. This article focuses on the use of templates to standardize the narrative section of SARs, as the Financial Crimes Enforcement Network (FinCEN) has identified SARs as a critical component in the fight against money laundering and has called on financial institutions to improve the clarity and accuracy of their SAR reporting. “The data derived from analyzing SARs is only as good as the information submitted in the actual SAR form,” said FinCEN Director James H. Freis, Jr., in an Oct. 2007 press release offering compliance tips for money services businesses (MSBs) and other SAR filers. Templates also vary by degree of structure. In the most structured templates for example, the entire narrative is pre-populated, and the investigator need only add key names, dates and amounts. Less structured templates provide more flexibility in layout and may or may not have a standardized opening and closing, but most have at least bullets of key points the investigator can incorporate into the narrative. Very straightforward SAR narratives are often naturally best suited for highlystructured templates. For example, a SAR reporting potential cash structuring lends itself easily to a structured template, given the cut-and-dry nature of the report. Similarly, a report for an unregistered MSB or check casher is another good candidate for a structured template, as the type of supporting information contained within this kind of report seldom varies. 32 acams today | On the other hand, SARs reporting Black Market Peso Exchanges (BPMEs) or terrorist financing may be more difficult to standardize in template format. However, even if structured templates are not utilized for the more advanced type of report, investigators may benefit from having a less structured template ]