Author Archives: Rachel Osborn

The Wheels on the BSA Go Round and Round: In Pursuit of the Well-Written SAR Narrative (Part 2)

Consider your BSA program as one of the wheels that supports the vehicle that is your compliance program. Within this wheel, there are several smaller components—the rim, axle, and spokes could perhaps be considered due diligence, training, and suspicious activity monitoring. For BSA, one of these crucial pieces is the suspicious activity report (SAR) narrative.

SAR narratives can be one of the more problematic areas of BSA compliance, but they are also an important tool for helping government authorities fight criminal financial activity. Missing, faulty, Continue reading →

In Pursuit of the Well-Written SAR Narrative

Suspicious Activity Report (SAR) narratives can be one of the more problematic areas of BSA compliance. However, not only are SARs an important tool for government authorities to help fight criminal financial activity, they frequently trip up financial institutions in examinations, leading to potentially costly fines and an adverse impact on their reputations, which is why it is crucial to make your SAR narrative as thorough as possible.

Furthermore, if you can get the SAR narrative down, you’ve gone a long way to demonstrating the Continue reading →

Is Your Institution Guilty of These 7 Deadly CTR Sins?

Wrath. Greed. Sloth. Pride. Lust. Envy. Gluttony. They’re often referred to as “capital vices” due to their tendency to lead to other sins.

While financial institutions deal more with money than with morals, there are several mistakes with currency transaction reports that can reflect unfavorably on your entire BSA program. Though CTRs may sound easy in theory, in the real world they can quickly become confusing, and it is important to correct these mistakes before they lead to larger issues.

Take a look at this Continue reading →

Throwback: In Pursuit of the Well-Written SAR Narrative

This week we’re throwing it back to our most popular blog post from last year. SARs are tricky things, but AffirmX Analyst Rachel Osborn has broken down the essential elements of a SAR into a step-by-step process in this timeless post. 

 

Suspicious Activity Report (SAR) narratives can be one of the more problematic areas of BSA compliance. However, not only are SARs an important tool for government authorities to help fight criminal financial activity, they frequently trip up financial institutions in examinations, leading to Continue reading →

Taming the Troublesome Continuing SAR Beast

Our most popular blog post of last year was about writing a knockout SAR narrative (you can find part one here and part two here). But when reviewing suspicious activity reports, we’ve noticed a large number of issues associated with those troublesome beasts known as continuing SARs. As such, it seems that a guide to writing a knockout continuing SAR narrative is judicious.

What Is a Continuing SAR?

When a financial institution identifies a suspicious activity, it must file a suspicious activity report—or SAR. But Continue reading →

Is Your Institution Guilty of These 7 Deadly CTR Sins?

Wrath. Greed. Sloth. Pride. Lust. Envy. Gluttony. They’re often referred to as “capital vices” due to their tendency to lead to other sins.

While financial institutions deal more with money than with morals, there are several mistakes with currency transaction reports that can reflect unfavorably on your entire BSA program. Though CTRs may sound easy in theory, in the real world they can quickly become confusing, and it is important to correct these mistakes before they lead to larger issues.

Take a look at this Continue reading →