Include all subject info in the narrative?

Posted By: Bec

Include all subject info in the narrative? - 01/04/18 09:36 PM

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
Posted By: rlcarey

Re: Include all subject info in the narrative? - 01/04/18 09:43 PM

I have been recently told - by whom?
Posted By: bcompliance

Re: Include all subject info in the narrative? - 01/04/18 09:44 PM

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
Posted By: Bec

Re: Include all subject info in the narrative? - 01/04/18 10:19 PM

A BSA officer from a different financial.
bccompliance, thank you for that reference. Pretty much nails it, in my opinion smile
Posted By: bcompliance

Re: Include all subject info in the narrative? - 01/05/18 01:22 PM

Next time ask them for a citation wink
Posted By: TryingtoComply

Re: Include all subject info in the narrative? - 01/05/18 09:44 PM

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.
Posted By: Bec

Re: Include all subject info in the narrative? - 01/09/18 08:59 PM

Thank you