Description:
While the multitude of SAR checkboxes are a challenge, even more intimidating can be writing the SAR narrative. What information should include? How detailed do I need to be? How long should it be? A myriad of questions can make this a daunting task. In this session, we will explore the FinCEN SAR Electronic Filing Instructions to make sure that we include all the required information so our narratives pass regulatory scrutiny. Beyond the regulation, we will also consider our target audience, law enforcement, and discuss best practices for constructing a SAR narrative that provide relevant, easy to understand information. A well crafted narrative puts law enforcement in the best position to connect the dots from our SAR to other related SARs and to conduct an investigation that puts them on the path to catching the bad guys.
Key takeaways:
- Identify regulatory requirements for narrative content
- Understand the relationship between the narrative and the rest of the SAR
- Develop a methodology for constructing the narrative
- Understand the impact of SAR amendments and corrections on the narrative
- Understand expectations for the narrative for continuing activity SARs
Presenters:
Brian Crow, CAMS
Brian Crow is managing partner and co-president for TCA Compliance and is a nationally recognized BSA/AML expert with a strong bank compliance management background and a welcome ability to provide focused educational support to TCA client banks. Crow most recently was BSA Administrator for a suburban Chicago bank, where his responsibilities included the bank’s annual assessment and audit documentation. Earlier, as Operations Officer at the same bank, Crow monitored AML activity and helped install automated AML software that allowed the bank to transition from paper to electronic CTRs. His activities were responsible for reducing debit card fraud by 95 percent at the bank. Mr. Crow has been, and continues to be, an education consultant for the Glia Group BOL Learning Connect program. It was in this role that Crow was recognized as a Bankers Online Guru in 2011. Like many of us, Mr. Crow began his banking career as a teller, working his way up to branch management responsibilities. He earned a B.A. degree from Concordia University, River Forest Illinois.
September 4, 2025