A suspicious activity report narrative should let a reader who never saw the case understand what happened, why it is suspicious and what the institution did about it.

That reader may be a law enforcement analyst a year from now, with no access to your systems and no one to call. The narrative is the only part of the SAR that tells the story. Everything else is fields.

The five questions

Who conducted the activity, what instruments were used, when it happened, where, and why it is unusual for this customer. Each answer belongs in the narrative, in plain language. FinCEN's own guidance adds a sixth: how the activity was carried out.

Most weak narratives fail on the last two. They describe the transactions in detail and never say why they matter for this customer, or how the pieces fit together.

A narrative, sentence by sentence

The SAR on our Home page is built from the Halvard Trading case. It opens with who and when: between March 3 and 21, Halvard Trading Ltd made 14 cash deposits, each just under the $10,000 reporting threshold.

It then answers why: the deposits are inconsistent with a declared turnover of $40,000 a year. It follows the money: funds were wired within days to three counterparties opened in the same period, one of which shares a director with Ostrava Metals, a partial match on the OFAC list.

It ends with context: public reporting links the owner to a customs fraud probe. Six statements, six pieces of evidence, and a reader who never saw the case can follow it.

Notice what the narrative does not say. It does not call the deposits structuring, and it does not say the director is the listed party. It states the facts, places them side by side and lets the reader see why the bank found them unusual. The filing deadline, 30 calendar days from initial detection in most cases, leaves no time to rewrite a narrative that overreaches.

Cite every sentence

Linking each statement to its evidence makes review faster and keeps drafts honest. If a sentence has no source, it does not belong in the report.

In Tipline, each statement in a draft points to an evidence item: the core banking record for the deposits, the KYC file for the turnover, the payments ledger for the wires, the registry for the director, the screening result for the match, the news archive for the probe. The reviewer clicks a sentence and sees the record behind it.

This changes the review. Instead of rereading the whole case to check a draft, the reviewer checks six links. A sentence that points nowhere stands out at once.

It also keeps the draft honest in the other direction. An agent that writes fluently can write a sentence that sounds right and is not supported. Requiring a citation for every statement turns that risk into something a reviewer can see: no link, no sentence.

What to leave out

A narrative is not a case file. It should not reproduce every alert, every screenshot or every step of the investigation. It should not speculate about crimes the evidence does not support, and it should not use internal codes a reader outside the bank cannot decode.

• Rule names, alert IDs and system codes without an explanation.

• Adjectives that carry the argument: "highly suspicious", "clearly illegal".

• Conclusions about intent that the evidence does not show.

• Transaction tables pasted in place of a summary.

• Facts with no date, no amount or no source.

Who writes, who signs

The SAR Drafting agent prepares the first draft from the case evidence. It never files. The draft arrives marked as awaiting analyst signature, and only an analyst can approve and file it.

The analyst edits freely. Changes are kept in the case history, next to the draft, so the team can see what the agent proposed and what the analyst wrote. Over time, that record shows where drafts need the most work.

A review checklist

Before a narrative is signed, the reviewer should be able to answer yes to each of these:

• Can someone outside the bank tell who, what, when, where, why and how?

• Does every factual sentence point to a piece of evidence?

• Are amounts, dates and names consistent with the SAR fields?

• Is the reason it is unusual stated for this customer, not in general?

• Is it free of internal codes and unexplained abbreviations?

What to do on Monday

Pick three narratives your team filed last quarter. For each sentence, write down the record it relies on. Count the sentences with no clear source. That count is the first thing to fix, with or without an agent.