When writing or reviewing a SAR/STR, it is important to ensure that the narrative is kept to the point; easy to read; and addresses the who, what, when, where, why, and how. This is because the narrative is the most crucial part of the SAR/STR, as it provides a clear and concise summary of the suspicious activity or transaction that triggered the report. The narrative should include all the relevant information that would help law enforcement or regulators to understand the nature and context of the activity or transaction, such as123:
The who: The names, addresses, account numbers, and other identifying information of the parties involved in the activity or transaction, such as customers, beneficiaries, intermediaries, or third parties.
The what: The type, amount, frequency, and purpose of the activity or transaction, such as cash deposits, wire transfers, check payments, or purchases of goods or services.
The when: The date, time, and duration of the activity or transaction, and whether it was a one-time occurrence or part of a pattern or trend.
The where: The location or channel of the activity or transaction, such as branches, ATMs, online platforms, or mobile applications.
The why: The reason or rationale for the activity or transaction, and why it was considered suspicious or unusual based on the customer’s profile, behavior, or expected activity.
The how: The method or mechanism of the activity or transaction, such as cash, check, debit card, credit card, cryptocurrency, or prepaid card.
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