Thread Starter: Anonymous
Title: Re: SAR Narrative -answering "why"
|
I recently received some advice from a consultant that SAR narratives should not directly state why the activity is suspicious. In other words, the filer should only mark reasons in the 'type of suspicious activity' boxes but should not say again in the narrative that the activity "appears to be structuring/mortgage fraud/a violation of X law because..." I've never heard of this approach before, and I don't know how this wouldn't land you with quality issues as FinCEN guidance and sample narratives suggest that you have to say WHY. Does anyone follow this practice?
|
|
|
|