SAR narrative writing: how detailed should the narrative be?

I'm training a new team of analysts and there's some debate about the appropriate level of detail in SAR narratives. Some argue that narratives should be comprehensive and include every relevant data point. Others say they should be concise and focused on the suspicious pattern.

What's your approach? Do you have a template or style guide? FinCEN's guidance is somewhat vague on this.

Agree with the 5 Ws approach. I'd add: avoid conclusions about criminal intent. Your job is to describe what's suspicious and why — not to prove a crime occurred.

Also, we've started linking related SARs by referencing prior filing numbers. FinCEN has specifically praised this practice as it helps them build cases across filings.

We use a standardized narrative template with sections for:

• Subject identification
• Account activity summary
• Description of suspicious activity
• Supporting documentation reviewed
• Relationship to prior SARs (if any)

This ensures consistency across analysts while still allowing professional judgment in describing the suspicious pattern. Happy to share our template privately if anyone's interested.

SAR narrative quality is probably the single area where FinCEN examiners focus most during BSA exams. A few principles:

The 5 W's framework — Every narrative should answer: Who is involved? What happened? When did it occur? Where did the funds go? Why is it suspicious? If you can answer all five clearly, your narrative is probably sufficient.

Be specific, not encyclopedic. A good narrative for a structuring case might be 300-500 words. A complex network case might need 1,000-1,500. But more words don't equal better quality. Include transaction amounts, dates, counterparties, and the specific behavior that triggered suspicion. Skip the customer's entire account history.

State what you know, not what you guess. Use language like "the transactions appear consistent with..." rather than "the customer is laundering money." You're reporting suspicious activity, not making a legal conclusion.

Law enforcement utility — Ask yourself: if an investigator reads this SAR with no other context, can they understand the suspicious activity and decide whether to investigate? If yes, your narrative works.

One practical tip: create narrative templates for your most common SAR types (structuring, third-party funnel, unusual wire activity). Templates ensure consistency and speed up the writing process, especially for junior analysts. But train your team to customize each narrative — cookie-cutter SARs that all read identically are a red flag for examiners.