Q: Do financial institutions need to repeat information in the SAR narrative that has already been included in other SAR data fields?
A: No. As stated in the SAR instructions, information provided in other sections of a SAR does not need to be repeated in the narrative unless necessary to provide a clear and complete description of the suspicious activity. Consistent with FinCEN’s SAR instructions, financial institutions should focus the SAR narrative on the information necessary to enable the reader to understand the activity reported, including what was unusual or irregular about the activity that caused suspicion. For example, granular detail (such as subject identification data) that is reported in the appropriate SAR data fields does not need to be repeated in the SAR narrative, unless such information is necessary to clearly describe the activity reported. Additionally, the SAR narrative may benefit from information about the suspicious activity that may not be readily evident from SAR data fields alone, such as an explanation about why the filer selected different characterizations of suspicious activity in the SAR data fields. Note, however, that FinCEN Advisories may include requests for financial institutions to incorporate certain terms in SAR field 2 (Financial Institution Note to FinCEN) and in the narrative to indicate a connection between the suspicious activity being reported and the subject of an advisory.
This Q&A was contained in the Interagency “Answers to Frequently Asked Questions Regarding Suspicious Activity Reporting and Other Anti-Money Laundering Considerations” dated January 19, 2021. This issuance may be found here: