Common Narrative Failures (and the Fix for Each)

If you read enough SARs, you notice something reassuring: the weak ones fail in the same handful of ways, over and over. That's good news, because a finite list of failure modes is a finite list of things to check for. In this lecture we walk through the failures reviewers and FinCEN flag most, and for each one we'll do the same thing, show the mistake and then show the fix.

The big four are conclusory statements that assert suspicion without facts, boilerplate language that could describe anyone, a missing how so the reader can't follow the money, and unexplained jargon and acronyms that only make sense inside your building. Let's take them in turn and turn each into a habit you can apply to your own drafts.

The first and most common failure is the conclusory statement. A narrative that says the customer engaged in suspicious activity, or the transactions were inconsistent with the customer's profile, has told the reader your conclusion but none of the facts that produced it. The reader can't verify a conclusion, and an investigator can't act on one.

The fix is mechanical: every time you catch yourself stating a conclusion, replace it with the underlying facts. Don't write the activity appeared structured; write between June first and June twentieth the customer made eleven cash deposits ranging from nine thousand two hundred to nine thousand eight hundred dollars across four branches. Let the reader reach the conclusion structured by seeing what you saw.

A good rule: if a sentence could be true of a thousand customers, it's conclusory, and you owe the reader the specifics.

The second failure is boilerplate, the recycled language that gets pasted from one SAR to the next because it's easy. The problem is that anything generic enough to fit every filing describes none of them well, and reviewers and examiners spot canned language instantly, because they've read it a hundred times. Boilerplate also tends to travel with the first failure, conclusory statements, since vague conclusions are exactly what's easy to reuse.

The fix is specificity. Write about this customer, these transactions, this institution, and this pattern, with the actual names, dates, amounts, and behaviors. The cure for boilerplate isn't better boilerplate; it's facts.

If you could swap your customer's name into someone else's narrative and not notice, your narrative isn't really about your customer yet.

The third failure is the missing how, which we flagged earlier as the element writers most often shortchange. A narrative can name the suspect, the amounts, the dates, and even the reason it's suspicious, and still leave the reader unable to follow how the money actually moved. That's a half-finished SAR, because tracing the money is what lets an investigator connect your filing to activity elsewhere.

The fix is to add the mechanics deliberately: how the funds entered the institution, how they moved once inside, and how they left. Cash deposited at three branches, swept into a single operating account, then wired in two transfers to an unrelated third party overseas. Read your own draft and ask, could a stranger draw the path of the money on a napkin from what I wrote?

If not, the how is missing.

The fourth failure is unexplained jargon. Acronyms, internal system names, product codes, and abbreviations that are second nature inside your institution are opaque to an outside reader, so spell them out the first time and skip the ones that don't matter. And there's a related pair of opposite errors worth naming together, because writers tend to fear one and commit the other.

One direction is too thin: a narrative missing elements, with so little detail that no one could act on it. The other is too padded: a narrative buried in irrelevant transaction history and background that drowns the actual suspicion. Both are quality problems.

The target is complete and relevant, every essential element present, and every sentence earning its place by advancing the story or supporting the suspicion. More words is not more sufficient; the right words are.

Recapping the failures and their fixes, because this list is your editing pass. Conclusory statements get replaced with the facts that produced them. Boilerplate gets replaced with language about this specific customer and these specific transactions.

A missing how gets the money flow added back, step by step, so a stranger could trace it. Unexplained jargon gets defined on first use. And watch the two-sided length error: not so thin that elements are missing, not so padded that the suspicion drowns.

Aim for complete and relevant. Run this checklist over any draft and most quality problems surface before a reviewer ever sees them. In the next lecture we leave the words behind for a moment and cover the rules you cannot get wrong, timing, deadlines, and the confidentiality prohibition on tipping off.