Should You File an AML Suspicious Activity Report Flowchart?
The decision on whether alerted transaction activity raises to the level of SAR filing is complex and requires a large amount of human judgment and analysis. But everyday thousands of AML analysts are expected to make these tough decisions with uncertain information and pressure from mounting workloads.
It’s easy to get distracted when gathering and processing all of the information involved in dispositioning an alert. Even though every case has unique aspects, and there are dozens of different factors that should be taken into account, there are essentially two questions that need to be answered when making a SAR filing decision.
- Are the transactions in line with the account’s purpose, profile, or nature of business?
- Is there any outside information that would increase the risk level related to the transaction or parties involved. This could be negative news, political exposure, sanctions, a high number of prior investigations, subpoenas, etc..
We have put together the below flowchart to outline how the above questions could be integrated into the decision making process at its most basic level. For a printable PDF version, please click here or on the below chart.
We had a lot of internal discussion on how to make this chart as simple, but as comprehensive as possible. The original chart was quite complex and had more than twice the number of decisions! But the chart is not meant to cover every possible scenario, or to outline how to conduct an AML investigation. It is meant to distill the core questions that need to be answered as part of every alert disposition; the decisions AML analysts must make multiple times a day, everyday.
Hope you find this helpful, and we would love to hear your feedback.
Additional SAR Resources:
- FinCEN Assessments Based Upon Suspicious Activity Report Filing Analysis
- FFIEC Online Manual – SAR Quality Guidance
- Guidance on Preparing a Complete and Sufficient Suspicious Activity Report Narrative (2003)
- FinCEN Interactive SAR Stats