AML Compliance in Practice: Suspicious Activity Reports

Explore money laundering, its predicate offenses, and the three stages—placement, layering, and integration—that conceal proceeds, and learn how risk analysis and suspicious activities reporting support the money laundering officer.

Introduce suspicious activity reports and their purpose for reporting money laundering and financing of terrorism to authorities and financial intelligence units, enabling law enforcement investigations by financial institutions.

Identify internal sources for suspicious activity, including screening lookback and transaction monitoring, and external sources like adverse media, law enforcement requests, and whistleblowers.

Identify red flags and atypical customer behavior across the customer lifecycle, from identity checks to transaction monitoring, highlighting sources of funds, high-risk jurisdictions, and potential money laundering schemes.

Learn how FATF recommendations drive suspicious activity reporting across the EU and US, including the fourth anti money laundering directive, the BSA, and 314(a)/(b) processes.

Learn how FIUs collect and analyze suspicious activity reports to support prosecutions, and how the Egmont Group facilitates international cooperation among FIUs worldwide.

Learn organizational considerations for SAR filings, weighing aggravating and mitigating factors, documenting decisions, and establishing procedures, escalation, quality assurance, typologies, and timelines for timely reporting.

Develop a robust, in good faith SAR decision-making process, incorporating account opening data, ongoing monitoring, red flags, and local laws to determine when to file.

Determine when to file a suspicious activity report by recognizing suspicion through unusual client behavior, transactions not aligned with KYC/CTD, or a predicate offense, guided by internal referrals.

Establish procedures to identify potential suspicious activity, conduct a formal review before filing, and file a SAR within 30 days after review determines suspicion, with cases expedited per regulator expectations.

Maintain strict confidentiality of suspicious activity reports to protect the investigation and prevent tipping off. Navigate cross-border sharing under FATF recommendation 21 and EU directives while preserving confidentiality.

Maintain comprehensive, self-explanatory documentation for suspicious activity reports, including evidence, transaction purpose, findings, and conclusions. Ensure access for investigators and regulators, independent of business pressure.

Explore the severe consequences of failing to file sar filings, including reputational, regulatory, and criminal risks for institutions and individuals, illustrated by real case studies.

Know your audience to tailor what you write, the information you present, and the level of detail to ensure readers understand the sars, improving reviewer efficiency and compliance outcomes.

Learn to craft a SAR narrative introduction that explains the activity, why it’s suspicious, who’s involved, when and where it occurred, what triggered the investigation, and red flags.

Understand how to craft a sar narrative body that clearly documents who, what, when, where, why, and how to support aml investigations.

Explain how to craft the SAR narrative conclusion by stating the filing reason, suspect activity amounts and time period, and any actions taken by the institution or law enforcement.

Enhance the suspicious activity report narrative's quality and accuracy by including all known subject information and clearly describing the factors that make activity suspicious for law enforcement.

Learn how to manage the client relationship after filing an SAR, including exit, freezing accounts, or ongoing monitoring, while following local laws and internal policies.

Notify senior management and the board about filed SARS, report to regulator or law enforcement as required, and provide sufficient, confidential summaries to support fiduciary duties and high-level risk responses.

Advance your AML compliance skills by applying SARS expertise to detect financial crimes and strengthen your organization's defenses against suspicious activity reports.