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Part VI

Suspicious Activity Information - Narrative *

Explanation/description of suspicious activity(ies). This section of the report is critical. The care with which it is completed may determine whether

or not the described activity and its possible criminal nature are clearly understood by investigators. Provide a clear, complete and chronological

description (not exceeding this p age and the next page) of the activity, including what is unusual, irregular or suspicious about the transaction(s), using

the checklist below as a guide, as you prepare your account.

a. Describe conduct that raised suspicion.

m. Indicate “Market where traded” and “Wire transfer identifier”

b. Explain whether the transaction(s) was completed or only attempted.

information when appropriate.

c. Describe supporting documentation (e.g. transaction records, new

n. Indicate whether funds or assets were recovered and, if so, enter the

account information, tape recordings, E-mail messages, correspon-

dollar value of the recovery in whole dollars only.

o. Indicate any additional account number(s), and any foreign bank(s)

dence, etc.) and retain such documentation in your file for five years.

d. Explain who benefited, financially or otherwise, from the

account number(s) which may be involved.

p. Indicate for a foreign national any available information on subject’s

transaction(s), how much, and how (if known).

e. Describe and retain any admission or explanation of the transaction(s)

passport(s), visa(s), and/or identification card(s). Include date, country,

provided by the subject(s) or other persons. Indicate to whom and

city of issue, issuing authority, and nationality.

q. Describe any suspicious activities that involve transfer of funds to or

when it was given.

f . Describe and retain any evidence of cover-up or evidence of an

from a foreign country, or transactions in a foreign currency. Identify

attempt to deceive federal or state examiners, SRO, or others.

the country, sources and destinations of funds.

g. Indicate where the possible violation of law(s) took place (e.g., main

r. Describe subject(s) position if employed by the financial institution.

s. Indicate whether securities, futures, or options were involved. If so,

office, branch, other).

h. Indicate whether the suspicious activity is an isolated incident or

list the type, CUSIP

number or ISID

number, and amount.

t. Indicate the type of institution filing this report, if this is not clear

relates to another transaction.

i. Indicate whether there is any related litigation. If so, specify the

from Part IV. For example, an IA that is managing partner of a limited

name of the litigation and the court where the action is pending.

partnership that is acting as a hedge fund that detects suspicious activity

j. Recommend any further investigation that might assist law

tied in part to its hedge fund activities should note that it is operating as

enforcement authorities.

a hedge fund.

k. Indicate whether any information has been excluded from this report;

u. Indicate, in instances when the subject or entity has a CRD or NFA

if so, state reasons.

number, what that number is.

l. Indicate whether U.S. or foreign currency and/or U.S. or foreign

v. If correcting a prior report (box in Item 1 checked), complete the form

negotiable instrument(s) were involved. If foreign, provide the

amount, name of currency, and country of origin.

in its entirety and note the corrected items here in Part VI

Information already provided in earlier p arts of this form need not necessarily be repeated if the meaning is clear .

Supporting documentation should not be filed with this report.

Maintain the information for your files.

Tips on SAR form preparation and filing are available in the SAR Activity Review at

Enter explanation/description in the space below. Continue on the next page if necessary. Do not include legal disclaimers in this narrative.

Fincen Form 101 - Suspicious Activity Report By The Securities And Futures Industries Page 3

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