BSA/AML Compliance: Writing the SAR Narrative

Recorded on April 24, 2014   |   With Ken Golliher

BSA/AML Compliance: Writing the SAR Narrative

With Ken Golliher
  • 1 Video
  • 3 PDFs
  • 2.0 hrs
Course description

Are you looking at a blank screen and thinking: Okay, I have to get this thing submitted by next Tuesday. If I don't tell my story well, all of this effort is nothing but an exercise. Where do I begin and what do I say?

Suspicious Activity Reports (SARs) incorporate a narrative requirement that is perhaps the most critical element in the report. "SAR quality" depends on whether that narrative is accurate and useful to law enforcement.

Years of experience as a banker doesn't necessarily mean that an individual is good at writing a story or explaining suspicious activity. This webinar is an attempt to help bankers organize and write a SAR narrative.

SAR filing is an explicit legal requirement for banks. The most critical part of any SAR is the "narrative" in Part V. That's where the bank tells the story and lists the supporting documentation on which the story is based.

The webinar revolves around guidance that FinCEN published several years ago, but has failed to update in the interim, particularly since the FinCEN SAR came on the scene.

  • Current resources from FinCEN
  • Items carried over from the SAR text boxes into Part V
  • The 5 W's and an H
  • Appropriate references for amended, corrected, and continuing SARs
  • Using the Excel compatible spreadsheet attachment
  • Using an "inverted pyramid" to organize the narrative
  • Connecting the "text boxes" to the narrative
  • Suggestions for content of general interest received by registrants in advance of the program

The program is designed for people who actually write or review SAR narratives. A two hour webinar will not make you into a great writer or editor, but it will make you more confident about this particular task.

Course Curriculum

BSA/AML Compliance: Writing the SAR Narrative
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Ken  Golliher
Ken Golliher

Ken is a principal with Pegasus Educational Services, LLC, a training firm headquartered in Louisville, Kentucky. He is an experienced banker with a unique ability to reduce complex legal concepts to plain English. He has explained the "why" and "how" of regulations to thousands of financial institution personnel and examiners. Ken's banking career began in 1972 and includes serving as a teller, commercial operations manager and as trust department legal counsel in a state and a national bank. For ten years he headed the education division of a regional consulting firm for financial institutions. He has served on the faculty of the LSU Graduate School of Banking, the OTS' Level I Compliance School and the FDIC's Advanced Consumer Protection school for examiners. He has presented seminars in more than 25 states and has served as an instructor at compliance schools sponsored by the Illinois, Indiana, Iowa, Georgia, Kansas, Kentucky, Nebraska, Oklahoma, Pennsylvania and Texas bankers associations. He is a member of the Society for Applied Learning Technology. He is also a "BOL Guru."