PRACTICAL SOLUTIONS
Likewise,
FinCEN guidance suggests that
financial institutions choose
to think of each reportable transaction
involving funds as an equation. Just as
there are two sides to an equation, there
are two sides to a reportable transaction:
the money coming in and the money going
out. Templates provide a gentle reminder to
investigators, new and seasoned, to remember that both sides of the equation merit
mention in a narrative.
Prior to crafting a template, the financial
institution also needs to determine how
to incorporate the templates into its investigative procedures. Will template use be
required, suggested or optional? Will use
vary by the type of activity being reported?
Will the experience level of the investigator
determine if template usage is required?
It is the answers to the above questions
that will guide the AML professionals
crafting the templates as to whether one
template with standardized opening and
closing paragraphs and bullets for suggested relevant information will suffice, or
if numerous “fill in the blank” structured
templates provide a stronger foundation
for the SAR program.
Once the templates are crafted, the financial institution still must consider such factors as training needs to ensure investigators
use the templates appropriately. Institutions
should also identify responsible parties to
handle such processes as incorporating
templates into appropriate procedures, periodically reviewing templates, establishing
precautionary measures to prevent document version control issues and updating
templates to reflect new FinCEN guidance
or regulatory reviews. The organization
should also define desired outcomes at the
onset of the project. A top-notch project
management plan pr