What are the requirements to develop a SAR narrative?

An effective narrative will include an introductory paragraph that provides information on the financial institution filing the SARs, the subject(s) of the SAR, the account(s
account(s
In bookkeeping, an account refers to assets, liabilities, income, expenses, and equity, as represented by individual ledger pages, to which changes in value are chronologically recorded with debit and credit entries. These entries, referred to as postings, become part of a book of final entry or ledger.
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), the date range of the suspicious activity, the nature of the suspicious activity, and the total of the suspicious activity.
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What are SAR requirements?

Under 12 CFR 21.11, national banks are required to report known or suspected criminal offenses, at specified thresholds, or transactions over $5,000 that they suspect involve money laundering or violate the Bank Secrecy Act. Similar regulations by other regulators apply to other financial institutions.
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What is a SAR narrative?

Introduction. The purpose of the Suspicious Activity Report (SAR) is to report known or suspected violations of law or suspicious activity observed by financial institutions subject to the regulations of the Bank Secrecy Act (BSA).
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What are the five key components of an effective SAR monitoring and reporting system?

A, C, and D are incorrect because the five key components of an effective SAR monitoring and reporting system are identification, managing alerts, decision making, completion and filing, and continuing monitoring/SAR filing on continuing activity.
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How do you write an effective SAR?

The Introduction
  1. Provide a brief statement of the SAR's purpose.
  2. Generally describe the known or suspected violation.
  3. Identify the date of any SARs previously filed on the subject & the purpose of that SAR.
  4. Indicate any internal investigative numbers used by the filing institution to maintain records of the SAR.
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How to Write a SAR Narrative



What information needs to be collected in order to accurately complete a SAR?

SAR filing options

Any name, address, social security or tax ID's, birth date, drivers license numbers, passport numbers, occupation and phone numbers of all parties involved with the activity. Part II - Suspicious Activity Information. Date Range and codes for the type of Suspicious Activity.
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What are the 3 levels of activity for filing a SAR for an MRB?

SAR reporting for MRBs is categorized under three key phrases that denote the type of activity involved: (1) marijuana limited; (2) marijuana priority; and (3) marijuana termination.
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What are the four overarching steps in the SAR process?

There are four overarching steps in the SAR process: gathering, documenting, analyzing, and sharing.
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What are two key components of identifying suspicious activity?

The five key components to an effective monitoring and reporting system are: Identification or alert of unusual activity (which may include: employee identification, law enforcement inquiries, other referrals, and transaction and surveillance monitoring system output). Managing alerts. SAR decision making.
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What is included in a Suspicious Activity Report?

A SAR is a Suspicious Activity Report, a piece of information which alerts law enforcement that certain client/customer activity is in some way suspicious and might indicate money laundering or terrorist financing. Submitting a SAR provides law enforcement with valuable information on potential criminality.
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What is the purpose of a SAR?

The goal of the SAR and the resulting investigation is to identify customers who are involved in money laundering, fraud, or terrorist funding. Disclosure to the customer, or failure to file a SAR, can result in very severe penalties for both individuals and institutions.
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When must a SAR report be filed?

Filing Timelines – Banks are required to file a SAR within 30 calendar days after the date of initial detection of facts constituting a basis for filing. This deadline may be extended an additional 30 days up to a total of 60 calendar days if no suspect is identified.
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What is required on a CTR?

Federal law requires financial institutions to report currency (cash or coin) transactions over $10,000 conducted by, or on behalf of, one person, as well as multiple currency transactions that aggregate to be over $10,000 in a single day. These transactions are reported on Currency Transaction Reports (CTRs).
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What can be attached as supporting documentation with a SAR?

As indicated in each of the SAR forms, financial institutions should identify in the SAR narrative the supporting documentation, which may include, for example, transaction records, new account information, tape recordings, e-mail messages, and correspondence.
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How do you identify suspicious activity?

Suspicious activities or behaviors may include, but are not limited to:
  1. Wandering around campus areas attempting to open multiple doors.
  2. Seeming nervous and looking over their shoulders.
  3. Entering restricted areas when not authorized or following immediately behind others into card-access areas while the door is open.
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Which of the following may require filing SAR quizlet?

SARs are required to be filed by the firm if the transaction appears to serve no business or legal and the transaction involves alone or in aggregate at least $5,000. 1) real estate fraud. 2) funding of terrorist activities. 3) use of insider information.
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What are the 3 stages of money laundering?

Money laundering is the process of making illegally-gained proceeds (i.e. "dirty money") appear legal (i.e. "clean"). Typically, it involves three steps: placement, layering and integration.
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What is a priority SAR?

“Marijuana Priority” SAR Filings. A financial institution filing a SAR on a marijuana-related business that it reasonably believes, based on its customer due diligence, implicates one of the Cole Memo priorities or violates state law should file a “Marijuana Priority” SAR.
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How long must you keep supporting documentation for SARs filed?

Both filers and joint filers are required to keep copies of the FinCEN SAR and their own supporting documentation for five (5) years after the date of filing.
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How do you create a subject access request to verify data about yourself?

If you wish to make a subject access request, there is no particular format for doing so - you can simply write to or email the organisation and ask it to provide all of the information about you it is required to disclose under the Data Protection Act.
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What is the difference between a CTR and a SAR?

A Currency Transaction Report (CTR) should be filed when a transaction or series of transactions exceeds the $10,000 threshold within a 24 hour period. A Suspicious Activity Report (SAR) must be filed when financial institutions become aware of suspicious behavior that could potentially be crime-related.
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What are the CIP requirements?

The CIP rule requires that a bank retain the identifying information obtained about the customer at the time of account opening for five years after the date the account is closed or, in the case of 7 Page 8 credit card accounts, five years after the account is closed or becomes dormant.
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Which of the following requires the filing of a Currency Transaction Report?

CTRs must be filed whenever a customer makes a currency transaction exceeding $10,000, or for multiple transactions if the sum exceeds $10,000 in one day.
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What four minimum pieces of information must you obtain when opening a new account relationship?

The CIP must specify the identifying information that will be obtained from each customer opening an account. This must include the customer's name, date of birth (for an individual), address, and identification number (31 CFR § 1020.220(a)(2)(i)). 4.
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What is structuring FinCEN?

Structuring is the breaking up of transactions for the purpose of evading the Bank Secrecy Act reporting and recordkeeping requirements and, if appropriate thresholds are met, should be reported as a suspicious transaction under 31 C.F.R. § 103.18.
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