Fillable Fincen Form 109 - Suspicious Activity Report By Money Services Business

Suspicious Activity Information - Narrative*

Part VI

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

of the activity, including what is unusual, irregular or suspicious about the transaction(s). Use the checklist below, as a guide, as you prepare your

description. The description should cover the material indicated in Parts I, II and III, but the money services business (MSB) should describe any other

information that it believes is necessary to better enable investigators to understand the suspicious activity being reported.

a. Describe conduct that raised suspicion.

or any exchanges of a foreign currency were involved. If so, identify

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

the currency, country, and sources and destinations of money.

c. Describe supporting documentation and retain such documentation

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

for your file for five years.

account numbers which may be involved in transfer of money.

d. Indicate a time period, if it was a factor in the suspicious transaction(s).

n. Identify any employee or other individual or entity (e.g., agent)

For example, specify the time and whether it occurred during AM or

suspected of improper involvement in the transaction(s).

o. For issuers, indicate if the endorser of money order(s) and/or

PM. If the activity covers more than one day, identify the time of day

when such activity occurred most frequently.

traveler’s check(s) is different than payee. If so, provide the individual

e. Retain any admission or explanation of the transaction(s) provided by

or entity name; bank’s name, city, state and country; ABA routing

the subject(s) or other persons. Indicate when and to whom it was

number; endorser’s bank account number; foreign non-bank name

given.

(if any); correspondent bank name and account number (if any); etc.

Retain any evidence of cover-up or evidence of an attempt to

p. For selling or paying locations, indicate if there is a video recording

deceive federal or state examiners, or others.

medium or surveillance photograph of the customer.

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

q. For selling or paying locations, if you do not have a record of a

government issued identification document, describe the type, issuer

main office, branch, agent location, etc.).

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

and number of any alternate identification that is available (e.g., for a

relates to another transaction.

credit card specify the name of the customer and credit card number.)

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

r. For selling or paying locations, describe the subject(s) if you do not

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

have the identifying information in Part I or if multiple individuals use

city of issue, issuing authority, and nationality.

the same identification. Use descriptors such as male, female, age, etc.

Indicate whether any information has been excluded from this

s. If amending a prior report, complete the form in its entirety and note

report; if so, state reasons.

the changes here in Part VI.

k. Indicate whether any U.S. or foreign instrument(s) were involved.

t. If a law enforcement agency has been contacted, list the name of the

If so, provide the amount, name of currency, and country of origin.

agency and the name of any person contacted, their title, their

Indicate whether any transfer of money to or from a foreign country,

telephone number, and when they were contacted.

Supporting documentation should not be filed with this report. Maintain the information for your files.

Enter the explanation/description narrative in the space below. If necessary, continue the narrative on a duplicate of this page or a blank page.

Tips on SAR form preparation and filing are available in the SAR Activity Reviews at w ww.fincen.gov/pub_reports.html.

Legal disclaimers will not be included in this narrative.

Fincen Form 109 - Suspicious Activity Report By Money Services Business - 2011 Page 3

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