1. AMLA Mid-Atlantic Chapter Event
Presenters: Special Agent Crystal Womble
Investigative Analyst Marilyn Willis

2. Topics Benefits of SARs Keys to writing complete SAR narrative
Downloads
Supporting Documentation
Examples of cases initiated by SARs

3. INTRODUCTION (WHO WE ARE)
The DCFCTF (DC Financial Crimes Task Force) is a working group made up of the United States Attorney’s Office, IRS-CI, HSI, US Secret Service, US Postal Service, the District of Columbia Metropolitan Police Department and other law enforcement agencies
The purpose of our working group is to evaluate all SARS filed in the District of Columbia area to determine that those have criminal potential
Two key functions:
De-confliction
2) Fosters information sharing and cooperation
Our group focuses primarily on Code A violations i.e. Bank Secrecy Act, Structuring and Money Laundering

4. DEFINITIONS
SAR – Title 31 U.S.C. § 5318 (g) requires a financial institution to report any transaction that it suspects 1) involves illegal activity, 2)is designed to evade the BSA requirements, & 3)has no business/lawful purpose
CTR – Title 31 U.S.C. § 5313 requires financial institutions to file a Currency Transaction Report for each deposit, withdrawal, exchange of currency or other payments in currency of more than $10,000 by, through, or to such financial institutions

5. REPORTING REGULATIONS
The Code of Federal Regulations requires banks to maintain a record of the SAR and supporting documentation for 5 years from date of the filing
A bank is required to file a SAR no later than 30 days after the date of initial detection by the bank of facts that may constitute the basis for filing a SAR
Federal law requires financial institutions to file CTRs with the Secretary of the Treasury within 15 days of the date on which the reportable transaction occurred.

6. Benefits of SARS (Bloomberg Article)
Financial institutions help to identify potentially problematic customers or transactions
Assist Law Enforcement with identifying problems and potential criminal activity
Assist with existing cases to identify financial activity

7. SAR Review Teams In Each Of IRS-CI’s 35 Field Offices
A Total Of 41 SAR Review Teams Throughout The Country
SAR Review Teams & Task Forces in US 94 Judicial Districts
56 Task Forces led by IRS-CI
More are being developed
All Types Of SAR’s Reviewed, Including
Bank SAR’s, MSB SAR’s,
Casino SAR’s, Securities and Futures SARs, etc.
Nationwide Approximately Employees Assigned To SAR-RT’s
Three “Lead Development Centers” Now Assigned To Do Proactive
Analysis of SAR Data. LDC’s In Denver, Indianapolis & Tampa
LDC’s Comprised of Intelligence Analyst & Agents Doing Analytical &
Case Development Work Only.

8. SAR Review Teams In Each Of IRS-CI’s 35 Field Offices
Since 2006, each year, more than 1 million SARs were downloaded and reviewed.
2012 = 1,117,418

9. SAR Review Teams and Task Forces
Multi-Agency-IRS-CI, FBI, ICE, DEA, USSS, FDIC, USDA OIG
Led by USAO
Meet monthly

10. SAR ‘must-haves’ Be concise & clear
Provide a detailed description of the known or suspected criminal violation or suspicious activity
Identify the essential elements of information (the 5 W’s)
Be chronological & complete

11. SAR NARRATIVE
The most useful section of the SAR is Part V, the narrative section
The narrative should include the following information:
Who is conducting the suspicious activity
What instruments or mechanisms are being used to facilitate the suspected transactions
When did the suspicious activity take place (list dates)
Where did the suspicious activity take place (list branches/addresses)
Amount involved (list activities)
Why does the filer think the activity is suspicious

12. Who is conducting the criminal or suspicious activity?
Describe additional details about the suspect(s) other than those provided earlier in the SAR form (Part I for SAR-MSB, SAR-SF & SAR-C or Part II for the depository institution SAR) :
Employer & occupation information
Relationship between the suspect & the filing institution
Length of the financial relationship 12

13. What instruments or mechanisms facilitate the suspect activity/transactions?
Identify & describe the transactions raising the suspicions of the financial institution. Examples include:
Cash deposits and/or withdrawals
Checks & other monetary instruments (money orders; traveler’s checks; cashiers or bank checks)

14. When did the criminal or suspicious activity occur?
If a one-time occurrence, identify
the date
If a pattern of activity occurred over a span of time, state when the activity first initiated and then describe the activity during the duration
Identify when the activity was detected

15. Where did the suspicious activity take place?
Identify the branch/department location or locations within the institution where the activity occurred (name of branch, the street address for each, where in the branch (ATM, teller, etc.)
Identify all account numbers & types
of accounts affected by the
transactions/activity
Indicate if suspect transactions involve
other domestic or international banks &
identify the banks, their locations,
account numbers, etc.

16. Why does the institution think the activity is suspicious?
First, describe the filer’s type of institution (i.e., XYZ Bank is a commercial bank with 400 branches located in 5 northeastern states; Send Money Quick is an international money transmitter with five offices in metropolitan Pretend City; We Make U Money is a securities broker, etc.)

17. Why does the institution think the activity or transaction is suspicious (cont.)?
Next, describe concisely but fully, why the institution considers the activity as suspicious
Be sure to include any relevant information about suspicious customer activity that the institution has in its files at the time the SAR is filed

18. How did the suspicious activity occur?
In a concise, accurate and logical manner, describe how the suspect transaction or pattern of transactions were completed
For account activity, provide as completely as possible an explanation of the cycle of funds including the source of the funds in the account & application of those funds

19. Additional Thoughts…
Remember to identify the teller or bank representative who spoke with customer
Narrate conversation with customer and response
If gave them CTR brochure, note that & maintain in file
Remember to save tape if possible
Identify transactions in narrative separately
Closure
Balance

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

21. Answers: What, Where, and When?
2. The Body
Provide the relevant facts about all parties facilitating the suspect activity or transactions
Answers: Who?
Identify all involved accounts and transactions in chronological order by date and amount – do not use or insert tabular objects, tables, or pre-formatted spread sheets
Answers: What, Where, and When?

22. 2. The Body (cont.)
Explain in detail the filer’s position that the activity or transaction is illegal or suspicious
Answers: Why?
Describe the method of operation of the subject:
Answers: How?

23. 3. The Conclusion Summarize the report & include:
Any planned or completed follow-up actions by the institution
Names & telephone numbers of persons with additional information about the reported activity
Location within the institution where all SAR-related records are maintained

24. Supporting Documents Requests process Documents to include Phone call
Fax
Secured (preference)
Documents to include
Mandate by BSA
Specific requests
Bank statements, signature cards, videos, deposit/withdrawal slips
Electronic responses preferred

25. Downloads
SAR database
Monthly
Formatted for distribution
Volume