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BSA / AML PlaybookTemplate

Template · 8 min

The BSA/AML SAR Narrative Scaffold

A human-reviewed template for who, what, when, where, why, how, missing facts, and evidence retention.

For: BSA/AML analysts and officers

Template preview

The BSA/AML SAR Narrative Scaffold

A human-reviewed template for who, what, when, where, why, how, missing facts, and evidence retention.

01

SAR confidentiality warning

  • Do not enter real SAR narratives, SAR drafts, SAR-supporting facts, investigation notes, customer transaction detail, alert detail, or anything that would reveal SAR existence into any public AI tool. Use this template with fictional, synthetic, public, or institution-approved redacted facts only, unless BSA, Compliance, Legal, and Information Security have approved the specific enterprise AI environment and use case.
02

SAR Narrative Scaffold

  • 1. One-line activity summary: What happened, during what period, and why it appears unusual.
  • 2. Who is involved: Subject/customer reference codes, roles, relationship to the institution, counterparties, business type, and relevant profile context. No real identifiers in AI prompts.
  • 3. What occurred: Activity type, instruments, transaction pattern, amount ranges, frequency, products used, and suspicious indicators.
03

When to use it

  • Drafting a human-reviewed SAR narrative scaffold from fictional, synthetic, public, or institution-approved redacted facts.
  • Recovering a narrative your reviewer kicked back for missing who, what, when, where, why, how, source evidence, or missing-fact analysis.
  • Separating reviewer sign-off, filing-deadline tracking, and retention evidence from the narrative body.
04

SAR Narrative Review Checklist

  • The narrative explains who, what, when, where, why, and how.
  • Every factual claim is supported by source documentation.
  • No AI-generated fact remains unsupported.
Section 1 of 5

SAR confidentiality warning

Do not enter real SAR narratives, SAR drafts, SAR-supporting facts, investigation notes, customer transaction detail, alert detail, or anything that would reveal SAR existence into any public AI tool. Use this template with fictional, synthetic, public, or institution-approved redacted facts only, unless BSA, Compliance, Legal, and Information Security have approved the specific enterprise AI environment and use case.
Section 2 of 5

SAR Narrative Scaffold

Use these fields as the working shell for analyst drafting and reviewer cleanup. The scaffold organizes facts; it does not make the suspicious-activity judgment or filing decision.

1. One-line activity summary
What happened, during what period, and why it appears unusual.
2. Who is involved
Subject/customer reference codes, roles, relationship to the institution, counterparties, business type, and relevant profile context. No real identifiers in AI prompts.
3. What occurred
Activity type, instruments, transaction pattern, amount ranges, frequency, products used, and suspicious indicators.
4. When it occurred
Date range, key event dates, escalation date, review period, and filing deadline tracker.
5. Where it occurred
Branch, channel, geography, account type, online/mobile channel, ATM, wire, ACH, cash, card, or other location/method context.
6. How the activity operated
Method of operation or typology: structuring, layering, funnel account, rapid movement of funds, business-purpose mismatch, third-party transfer ring, unusual cash activity, or other pattern.
7. Why it is suspicious
What changed from expected behavior, what does not fit the customer profile, what source evidence supports concern, and what reasonable explanation was unavailable or insufficient.
8. Source evidence used
Alert ID, case note reference, transaction report reference, customer profile reference, CDD/EDD source, analyst notes, and supporting-documentation location.
9. Missing facts / verify before filing
Open questions, unsupported claims, AI-introduced language to remove, and facts requiring analyst confirmation.
10. Reviewer sign-off
Analyst, reviewer, BSA officer or designee, review date, final filing decision, retention location, and deadline.
Section 3 of 5

When to use it

  • Drafting a human-reviewed SAR narrative scaffold from fictional, synthetic, public, or institution-approved redacted facts.
  • Recovering a narrative your reviewer kicked back for missing who, what, when, where, why, how, source evidence, or missing-fact analysis.
  • Separating reviewer sign-off, filing-deadline tracking, and retention evidence from the narrative body.
Section 4 of 5

SAR Narrative Review Checklist

  • The narrative explains who, what, when, where, why, and how.
  • Every factual claim is supported by source documentation.
  • No AI-generated fact remains unsupported.
  • No real SAR, SAR draft, SAR-supporting fact, customer, account, transaction, alert, or investigation detail was entered into a public AI tool.
  • The analyst owns the suspicious-activity judgment.
  • The BSA officer or designated reviewer approved the final narrative.
  • Supporting documentation and final review evidence are retained according to policy.
Section 5 of 5

Source evidence and retention fields

Banks must retain SARs and supporting documentation for five years from the filing date and make supporting documentation available to FinCEN or appropriate agencies upon request. Use these fields to make the evidence location explicit.

Alert / case reference
Internal alert ID, case ID, or investigation reference.
Supporting-documentation location
Repository, case-management folder, or system path where source evidence is retained.
Final narrative reviewer
Name and role of the analyst, reviewer, BSA officer, or designee.
Filing decision and date
Final file / do not file / continue review decision and approval date.
Retention owner
Person or team responsible for preserving the final narrative, support file, and review evidence.
BSA / AML Playbook

The artifact is the start. The course is where it sticks.

Use this template, then walk through the practice loop in the AiBI-Foundation course — the same prompts, with reviewed work you can take to your team.

Start your BSA / AML pathBack to the playbook
The BSA/AML SAR Narrative Scaffold — BSA / AML Playbook — The AI Banking Institute