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#2159263 - 01/04/18 09:36 PM Include all subject info in the narrative?
Bec Offline
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Bec
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The Great White North
When completing a SAR, I have been recently told that it is necessary to include all personal information (SSN, DOB, Address, Phone #, etc) in the narrative. The reason was that when law enforcement obtain copies of SARS, they only receive the narrative portion and the including of this information is necessary for them to conduct their investigation. When I look at examples of well written SAR narratives from FinCEN, there is no personal information to that extent listed in them. Has anyone else heard of doing this or already does this. I am clenching as I await your responses smile
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#2159267 - 01/04/18 09:43 PM Re: Include all subject info in the narrative? Bec
rlcarey Online
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rlcarey
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Galveston, TX
I have been recently told - by whom?
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#2159268 - 01/04/18 09:44 PM Re: Include all subject info in the narrative? Bec
bcompliance Offline
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I don't unless I have information pertaining to someone who is not a subject, but the information may be helpful to law enforcement. From the checklist listed at the end of the SAR filing instructions:

"Information provided in other sections of the FinCEN SAR need not be repeated in the narrative unless necessary to provide a clear and complete description of the suspicious activity."

https://www.fincen.gov/sites/default/fil...Alone%20doc.pdf
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#2159280 - 01/04/18 10:19 PM Re: Include all subject info in the narrative? Bec
Bec Offline
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A BSA officer from a different financial.
bccompliance, thank you for that reference. Pretty much nails it, in my opinion smile
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#2159318 - 01/05/18 01:22 PM Re: Include all subject info in the narrative? Bec
bcompliance Offline
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Next time ask them for a citation wink
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#2159469 - 01/05/18 09:44 PM Re: Include all subject info in the narrative? Bec
TryingtoComply Offline
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I don't repeat information on a suspect; however, I will include information on others if I feel it is relevant.

I attended the ACAMS conference last year and a panel of law enforcement advised not to repeat anything in the narrative that already exists in other sections of the report. The information in the narrative comes across to them in one continuous line and is difficult for them to read. They asked that we keep that in mind when writing narratives. They dislike redundancy. They just want to get to the important stuff.
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#2159856 - 01/09/18 08:59 PM Re: Include all subject info in the narrative? Bec
Bec Offline
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Bec
Joined: Jul 2010
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The Great White North
Thank you
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