What should the narrative section (Part VII) of the SAR include?
The narrative section is one of the most critical sections of the form. Information about the activity should be as complete as possible, and: • Describe what is unusual, irregular or suspicious • Describe conduct that raised suspicion • Explain if transaction was attempted or completed • Explain who benefited from transaction • Describe/retain explanation provided by subject • Describe the subject • Describe and retain any evidence • Include any correspondent bank name/account information; names/locations of business entities; names of cities, countries and foreign financial institutions linked to the transaction, especially if funds transfer activity is involved; and account numbers and beneficiary names. It is also essential to provide descriptive information about the suspect. An MSB should not include attachments in place of a narrative. Attachments are supporting documents for its own records.
