The SAR narrative and the FinCEN fields drafted from the case, checked three ways, signed by the BSA Officer
SARs drafted from the case and checked three ways, ready for the BSA Officer to sign.
See one case, screen by screen ↓SAR Narrative & Filing drafts the SAR narrative and the FinCEN SAR fields from the case for BSA officers. Seven agents read the case, write the narrative sentence by sentence with the W it answers and its citation, fill the fields with their sources and check every amount, date and name against the fields and the bank's records. The BSA Analyst prepares, the SAR Quality Reviewer passes it, and only the BSA Officer signs and files.
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The SAR narrative is the part of a suspicious activity report that law enforcement reads, and it is written by hand. The BSA analyst re-reads the case, the alerts, the account ledger, the deposit tickets, the teller notes and the wire records, writes who, what, when, where, why and how, then keys the same amounts, dates and names again into the FinCEN SAR fields and builds a transaction table. A quality reviewer checks it all again before the BSA Officer signs. Every case runs on its own clock: 30 calendar days from detection, 60 when no suspect is identified.
The risk sits in the copies. When two alerts overlap, the same deposit is counted twice, and a narrative and an Item 29 that both say $186,400 next to a ledger that adds to $184,900 is what a QC reviewer or an examiner finds. Since the October 2025 interagency SAR FAQs, cash near $10,000 is not enough on its own; the narrative has to show why the bank suspects the activity was designed to evade reporting. And nothing about a SAR may reach the customer: one branch note that mentions a report is a disclosure.
Estimated split for one structuring SAR at a community bank, by hand and with the solution.
Seven agents read the case, draft the cited narrative and fields, and check every number; the analyst prepares and the BSA Officer signs.
Tessaly Community Bank detected suspected structuring by Northgate Resale Supply LLC on October 1, 2026: 24 cash deposits at four branches, every one below $10,000, and six wires out to an auto dealer. Case TCB-2026-0418 is due Saturday, October 31. Here is Tuesday, October 27, screen by screen, in the working solution.
Fourteen SARs are in preparation, 4 are due within 7 days and 5 need Dana. Overnight the agents drafted 3 narratives and read 47 documents. The queue is ranked by days left, and each case says what the agents found: Northgate Resale Supply LLC, structuring, 4 days left.
“Needs you — narrative says $186,400, the ledger adds to $184,900.”
The case reader read 47 documents from six systems; the drafter wrote 10 sentences with 20 citations, in an introduction, a body and a conclusion. Each sentence is softly tinted by whether it answers who, what, when, where, why or how, and the coverage line counts them: who 2, what 4, when 3, where 2, why 3, how 3. Beside it, the FinCEN SAR fields it feeds, each with its source.
Item 29, $186,400: “Disagrees with the ledger.”
Dana lights only the why sentences and clicks the September 18 citation. Teller note TN-0918-HS opens from document imaging, written at 1:42 PM by R. Almquist at the Harlan Street branch, with the cited words marked. The case reader read it at 0.97 confidence.
“Customer asked what amount gets reported to the government. … He took back $5,500 of the $14,600 and said he would deposit it somewhere else. Deposited $9,100.”
Eleven sources from six systems: the customer profile, the teller identification record, the account ledger, two alerts, 24 deposit tickets, the teller note, six wires, the October 6 request for information, six currency transaction reports and the records policy. The open document shows the cited line and the sentences that cite it.
Nine facts sit in three columns: the narrative, the FinCEN fields and the systems of record. Seven agree. Two do not, and the checker names the cause: deposit TX-880508, $1,500 in cash at East Fenwick on September 24, sits in both alert AL-77120 and alert AL-77164, and the draft added the two extracts — 15 + 10 deposits, $113,200 + $73,200. The ledger has 24 deposits and $184,900.
The consistency checker never resolves a disagreement itself; its tolerance on amounts is $0.
Dana chooses “Use the ledger: 24 deposits, $184,900”. The narrative, Item 29 and the attachment change together, with reason CN-01, “Use the system of record”. All nine facts agree, and the duplicate stays visible, struck through, so the reviewer sees what changed. Keeping the draft amount would have needed an override reason code, OV-01 to OV-04.
The three subjects are listed as BSA E-Filing will receive them, each field naming the document it came from. No source holds Lena Treloar's TIN or date of birth, so the field mapper checks the “unknown” box. Critical fields 41 of 41, 2 marked unknown, the narrative within 17,000 characters and one CSV attachment: checked against the BSA E-Filing rules, passed.
The field mapper never guesses a TIN or a date of birth — it checks “unknown”.
Tessaly's checklist v3.2 shows 14 of 14 checks passing, each with its evidence and its rule. The structuring check cites teller note TN-0918-HS and the split deposit on September 18, under the October 9, 2025 SAR FAQs, Q1. Lucas agrees check by check and passes QC; he could return it with a reason code, QC-01 to QC-05, but he cannot edit the narrative.
Check 6: “Structuring: evidence the activity was designed to evade reporting, not only amounts near $10,000.”
Prepared by Dana Whitlock, reviewed by Lucas Brandt, signed by Renee Coyle, who did neither. After her attestation, the E-Filing clerk checks the filing against the BSA E-Filing rules, submits it at 10:44 AM and records the acknowledgment at 10:52 AM, BSA ID 00000248816407. The SAR is sealed with its 47 supporting documents.
“Filed on day 26 of 30 and sealed until October 27, 2031.”
The guard renders each customer-facing view of Northgate and checks it for a flag, a note, a status or a hold reason that could tip off the customer. The teller sees “Questions about a letter: refer to the BSA Office” and cash deposits accepted as usual; online banking shows the October 6 letter and no notices; the partner program portal shows only its own referral, QP-2610, as “review complete”, with no case number and no filing decision.
“Nothing reveals a SAR.”
The same Northgate SAR, seen by the four people around it — what their month looked like, and what it looks like now.
Seven agents read the case, draft the cited narrative and fields, and check every number; the analyst prepares and the BSA Officer signs.
Reads the case file, the alerts, the ledger, deposit tickets, teller notes, wires, the customer profile, letters and currency transaction reports, and cites every value to its page.
Writes the introduction, body and conclusion, tagging each sentence with the W it answers and its citations, and proposes the changes the analyst asks for.
Fills Parts I–V of the FinCEN SAR from the case and builds the transaction CSV attachment from the ledger.
Compares every amount, count, date, name and branch across the narrative, the FinCEN fields and the systems of record, and names the cause of any disagreement.
Runs the bank's 14-check list, FinCEN's narrative guidance and the October 2025 SAR FAQ checks, citing each result.
Seals each SAR, logs every opening, and every 15 minutes reads each customer-facing output linked to a sealed case for anything that would reveal a SAR, and holds it.
Builds and submits the filing after signature, reads FinCEN's acknowledgments, writes the BSA ID onto the case, routes a rejection to its preparer in plain words and seals the SAR for five years.
Signs and files; never on a SAR she prepared. The agents propose; a named person decides.
Ask about any case, sentence, field or rule, or tell the drafter what to change. Every answer points to its source, and nothing in a SAR changes until a named person accepts it.
Why is the amount $184,900 and not $186,400?
One deposit was counted twice. Deposit TX-880508, $1,500 at East Fenwick on September 24, is in alert AL-77120 (ends September 24) and in AL-77164 (begins September 24). The draft added the two extracts — 15 + 10 deposits, $113,200 + $73,200. The core banking ledger has 24 deposits and $184,900.
Does Northgate meet the structuring standard after the October 2025 FAQ?
Amounts near $10,000 alone would not be enough (FAQ Q1, October 9, 2025). Here there is evidence of intent: on September 18 Gavin Treloar asked a Harlan Street teller what amount is reported, then took back $5,500 of $14,600 and deposited it at Millbrook that afternoon. QC check 6 cites both.
Which SARs are due this week?
Four, all on the 30-day clock: Marisol Fenwright (day 27, due Friday, waiting for the BSA Officer), Northgate Resale Supply LLC (day 26, due Saturday), Quillfield Pay program (day 25, with QC) and Renmark Logistics Inc. (day 24, needs you). Three are already escalated at day 25.
List the wires by date
Proposed sentence, for you to accept or reject: “Funds left the account in six outgoing wires to Pellham Auto Group Inc., an auto dealer at an unaffiliated bank, each described as ‘inventory’: $28,400 on September 4, $31,900 on September 15, $26,500 on September 21, $29,700 on September 29, $27,300 on October 2 and $27,500 on October 9, 2026, for a total of $171,300.”
13 screens from the working solution, on its sample data. Pick one to see it large.
The clocks, checks and limits every SAR is held to are settings. Rules fixed by regulation stay fixed — 30 days to file, 60 with no suspect, five years to keep — and every change is proposed, approved and versioned.
| Setting | Default | Choose from |
|---|---|---|
| First escalation — BSA Officer | Day 20 | From day 10 to the day before the second escalation, one day at a time |
| Second escalation — Chief Risk Officer | Day 25 | Up to day 29, one day at a time |
| Batch time for BSA E-Filing | 4:00 PM | 4:00 PM · 12:00 PM · 9:00 AM |
| Confidence threshold for extracted values | 0.90 | 0.70 to 0.99, in steps of 0.05 |
| October 2025 FAQ checks | On | On · Off |
| Continuing-activity filings | Elected for cases the BSA Officer marks | On · Off |
| Deputy BSA Officer co-signs when Item 29 is over $1,000,000 | Off | On · Off |
| Three different people on every SAR | On | Always on |
Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.
“demo” = seen in the working solution, on its sample data · “target” = the design goal, measured in the live solution · “estimated” = our estimate · “typical” = published figures (FinCEN SAR statistics, fiscal year 2024 — 2.6 million SARs filed by depository institutions; FinCEN's paperwork-burden estimate for the FinCEN SAR — 25 to 315 minutes for final preparation of one report). Rules named: 31 CFR 1020.320; FinCEN, Guidance on Preparing a Complete & Sufficient SAR Narrative (2003); FinCEN, Federal Reserve, FDIC, NCUA and OCC, SAR FAQs (October 9, 2025). Banks, partner programs, companies, people, account numbers and BSA IDs named on this page are fictional — characters and sample data in the working solution.
SAR Narrative & Filing drafts the SAR narrative and the FinCEN SAR fields from the case for BSA officers. Seven agents read the case, write the narrative sentence by sentence with the W it answers and its citation, fill the fields with their sources and check every amount, date and name against the fields and the bank's records. The BSA Analyst prepares, the SAR Quality Reviewer passes it, and only the BSA Officer signs and files.
FinCEN's narrative guidance asks for who, what, when, where, why and how, in an introduction, a body and a conclusion, in plain text with no “see attached” and no tables. The coverage line counts the sentences that answer each W, and a missing one becomes a question from the drafter to the analyst. Transaction detail goes in the CSV attachment, not the narrative.
Under 31 CFR 1020.320 a bank files within 30 calendar days of initial detection, up to 60 when no suspect is identified, keeps the SAR and its supporting documents five years, and never discloses a SAR. Every open case shows its day and due date, and escalates to the BSA Officer at day 20 and the Chief Risk Officer at day 25, both settings. Continuing-activity filings are planned only where the bank's policy elects them.
The interagency FAQs say cash near $10,000 is not on its own a basis for a SAR. The QC checker's structuring check asks for evidence the activity was designed to evade reporting, and cites it — in the sample case, the teller's note and the split deposit on September 18.
The consistency checker shows the disagreement and its cause, and never resolves it. The analyst corrects from the system of record with a correction code, or keeps the draft with an override code that the BSA Officer sees at signature.
Each SAR is sealed, access is by case role, and every opening is logged with a reason. The confidentiality guard reads customer-facing outputs — letters, branch call notes, partner program messages, online banking notices — for anything that would reveal a SAR and holds it. A customer view check shows what a teller, the customer and a partner program see.
Yes. The agents may not sign, file, pass QC, resolve a disagreement or contact a customer. Three different people prepare, review and sign each SAR, the BSA Officer can decide not to file with a reason code, and agent and prompt versions, confidence thresholds and override reason codes are settings for your model risk team to review.
The Agentic Solution Engine builds and deploys it from your requirements and documents — your SAR narrative template, QC checklist, escalation policy and a sample of past SAR cases — and it goes live once every quality gate has passed. We will walk you through it on your own cases first.
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