Importance of SAR Reporting to Law Enforcement Investigations

Analysis of SARs plays a critical role in various types of law enforcement investigations. Regardless of the underlying crime, SARs serve as a vital tool for identifying and tracking funds derived from criminal activity. SAR data provides valuable pieces of information that are similar to pieces of a puzzle - each separate piece helps investigators identify complex and sophisticated relationships between people, businesses, locations and assets. Although it is sometimes impossible to obtain 100 percent of the information requested on SAR forms, a concerted effort to obtain specific .puzzle pieces. is very valuable to law enforcement.

Filers should strive to obtain and record as much suspect information as possible. When a suspect exists, always enter suspect related data in the appropriate "Suspect " portion of the form. A recent review of filings indicates that some forms actually contain no identifying names for the suspect but rather have references such as "See Part V" or "See next Page" in the suspect portion of the form. This limits investigative capabilities used to identify suspects and to allow accurate data retrieval/query efforts by law enforcement. Using only a first initial rather than a full first name also poses problems in accurately identifying suspects. Whenever possible, try to obtain complete first names for all suspects. Address information should contain street numbers and apartment numbers if known. Foreign countries should be entered using the attached database standardized country codes. Suspects. occupations also provide high quality leads for law enforcement investigators. When known, vital information should be captured in the suspect area of the SAR form.

Another critical piece of the puzzle is found in identification numbers. Passport numbers should reflect the country of issue in the "Issuing Authority" section using the standardized country codes. Alien registration numbers contain a letter of the alphabet preceding the actual number . always enter the letter along with the number.

A major element that increases the utility of SARs for law enforcement is the narrative information or .description of activity.. If the activity involves wire transfer transactions, include destination city, state and country as well as names of banks and beneficiary persons or businesses. Of particular value are names of foreign financial institutions and the account numbers associated with funds transfers. The use of money orders, traveler's checks, foreign currency or other monetary instruments should also be noted within the activity description. If stocks, bonds, letters of credit, investments, commodities, etc. are involved, this should also be noted as this helps identify methodologies associated with criminal activities.

SAR filers who make reasonable efforts to obtain, record and report the key information outlined above will enhance the ultimate utility of SARs for law enforcement purposes.

Excerpted from SAR Activity Review Issue 3, page 37