So many times when we are taking photographs of our subjects, the focal point is blurred to the point that what we are focusing on doesn’t show through the way we thought or hoped. For example, I took what I thought was going to be a winning shot of my granddaughters only to realize, after the fact, that there was an unflattering image of my dog in the background. I missed it because I was only focused on the girls. Now, there are techniques that can be used to bring the subject in focus, but if we don’t know what they are, we are less likely to get it right. We need to practice, practice, and then practice some more. If we truly want to be good at taking the shot, we need to make sure we hone our skills. Sometimes, we need to put a light on the subject to be able to see it better; other times we need to move in closer, so we can fill up our frame with our intended subject. We need to focus on the details of the surroundings so that we can pinpoint what areas we want the intended viewer to focus on. We need to understand what we are viewing through our lens and then make the necessary adjustments.
These same concepts hold true when we are reviewing potentially suspicious activity. We need to ask ourselves what it is that we are trying to see. Do we only want a blurred image, or do we want to sharpen our skills and get a better focus on the details?
Let’s say you have a customer that deposits $50,000 in cash that appears to be damp and moldy. Does this mean that they are doing something shady and suspicious? Or could they be an executor to an estate for their grandparents who lived through the Great Depression and kept cash hidden at home in the basement because they wanted to be “safe” if anything like that should happen again? Look at the big picture. What is happening in the foreground and the background? Does the activity make sense? Is this typical behavior for the customer, and if so, why? Just like capturing the best shot, you must look at things from multiple angles.
Sometimes we have a preconceived idea of what we think we are going to see, and we can become desensitized to the image in front of us. Therefore, it is important to look at the activity with impartial eyes. Use the lens of your knowledge of suspicious activity and apply it appropriately to all customer transactions. Break the mindsets of “it can’t be suspicious because we know that customer,” or “that customer can’t possibly have that much cash on hand, so it must be suspicious.”
There are times, however, where things are exactly as they seem, as in the example listed above. Maybe there isn’t any “funny business” happening, but without investigating, there is no way to ascertain that for certain. To get a clear picture, take the time to review the customer relationship, including the length of time they have been your customer, the nature of the business or their occupation, their account activity, expected transactions, and customer behavior. If you decide that all is as it seems and there is no suspicious activity, make sure you document the date the activity was identified, why the activity was investigated (such as unusual cash activity), areas you reviewed during your investigation, and what next steps you plan to take, such as monitoring the account to determine if the activity continues. This information should be a part of your SAR exception file. This file will evidence that you identified a potential SAR reportable issue and that you completed the due diligence necessary to make an informed decision on not filing a SAR. If you find that the activity is indeed suspicious enough to warrant a SAR filing, drafting a comprehensive SAR narrative is just as important as the investigative process. Be specific in explaining why you are filing the SAR, and be sure to answer the important questions in the narrative: Who is the subject? What is the activity? Where did the activity occur? When did the activity take place? How were the transactions conducted? Also include why you are filing the SAR and why the activity occurred if you have knowledge of the reason (for example, the customer tells you that they don’t want the government to know how much cash they have so they’re only going to deposit it a little at a time). Any documentation you have that will support the filing should be referenced in your SAR narrative as well. Be thorough in your reporting and be sure to complete as much information as possible within the SAR report, including noncritical fields (phone number, email address), especially if the information is readily available.
YOU are the key to a good SAR investigation. Pick up your camera, adjust the focus, fill the lens, and take that snapshot.