On Compliance: Make the most of your SAR writing efforts
Tips for how to catch the eye of law enforcement agents and still meet regulators’ guidance in your suspicious activity reporting—and also on when disclosure is allowed.
Suspicious activity report writing and filing is arguably one of the most important responsibilities of financial crimes professionals. In 2018, FinCEN Director Kenneth A. Blanco testified that Bank Secrecy Act reporting, particularly through CTRs (currency transaction reports) and SARs, is critical in ensuring the protection of the U.S. financial system, keeping our country strong and prosperous, and keeping our families and communities safe from harm. As larger financial institutions continue to implement sophisticated tools and software to detect illicit transactions, the bad actors are shifting toward credit unions and other smaller community financial institutions with the hope that their activity will not be detected.
While financial crime professionals fully understand the importance of SARs, compliance teams have many challenges when knowing what procedures to follow for SAR completion and disclosure. For example, there seems to be ongoing conflict between what law enforcement wants in a SAR and what the regulators require. With approximately two billion SARs filed each year, how can a credit union increase the chances that the SARs it labors to write will actually be read?
Four Ways to Balance Capturing Attention and Being Compliant
Law enforcement has repeatedly stated in training sessions, conferences and interviews that to get their attention and possibly lead to them opening an investigation or using a SAR in an ongoing case, a credit union should do the following:
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