Suspicious Activity Report (SAR) Decision and Filing Worksheet
A Suspicious Activity Report (SAR) Decision and Filing Worksheet for documenting account review, filing decisions, and the audit trail behind a FinCEN SAR. Use it to capture the facts, rationale, and filing details in one place.
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Overview
This worksheet is for documenting the review of suspicious or unusual account activity, the decision to file or not file a SAR, and the evidence behind that decision. It gives investigators a structured place to record the case reference, review date, reviewer identity, account and activity details, decision rationale, supporting documents, related accounts, prior case history, and filing information.
Use it when an alert, referral, or manual review needs a defensible record that can stand up to internal audit, compliance testing, or examiner questions. The template is especially useful when multiple people touch the case, when the activity spans several dates or accounts, or when the final decision depends on a chain of indicators rather than a single event.
Do not use it as a generic incident log or as a substitute for the actual SAR filing process. If the matter is not a suspicious activity review, or if your organization does not require a formal decision record, a lighter case note may be enough. Keep the worksheet focused on the minimum necessary information: collect only the PII and supporting evidence needed to support the decision, and use clear validation for dates, counts, and filing identifiers. The result should be a clean audit trail that explains what was reviewed, what was decided, and what happened next.
Standards & compliance context
- This template supports an audit trail that helps document SAR decisioning and filing activity for AML compliance workflows.
- Use the minimum necessary principle by collecting only the account, transaction, and identity details needed to support the review.
- If the worksheet is exposed to employees or external users, apply access controls and retention rules consistent with your institution's compliance program.
- Keep reviewer identity, decision rationale, and filing timestamps accurate so the record can support internal audit and regulatory examination.
General regulatory context for orientation only — verify current requirements with counsel or the relevant agency before relying on this template for compliance.
What's inside this template
Submission Notice
This section establishes the case identity and who performed the review, which is the starting point for any defensible audit trail.
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Case Reference Number
Internal case or alert reference used to track the review.
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Review Date
Date the suspicious activity review was completed.
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Reviewer Name
Name of the compliance analyst or investigator completing the worksheet.
- Reviewer Role
Account and Activity Review
This section captures the account context, activity window, and observable indicators that drove the suspicious activity assessment.
- Account or Relationship Type
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Activity Start Date
Approximate date when the unusual activity began.
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Activity End Date
Approximate date when the unusual activity ended or was last observed.
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Summary of Anomalous Activity
Describe the unusual patterns, transactions, or behaviors observed. Include only facts relevant to the review.
- Suspicious Activity Indicators
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Estimated Number of Relevant Transactions
Approximate count of transactions reviewed for this case.
SAR Decision
This section records the outcome of the review and the reasoning behind filing, escalation, or closure.
- Decision
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Decision Rationale
Explain the basis for the decision, including key facts, thresholds, and why the activity is or is not suspicious.
- Primary Filing Reason
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Escalation Reason
Describe what additional information or review is needed before a final decision can be made.
Supporting Evidence and Review Notes
This section ties the decision to documents, related accounts, and prior history so the case can be reconstructed later.
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Supporting Documents
Upload relevant case notes, transaction reports, screenshots, or other supporting records.
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Related Accounts or Parties
List only the account identifiers or relationship references needed for the case record. Do not include full sensitive identifiers unless required by policy.
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Prior Case History
Summarize any prior alerts, investigations, or known patterns relevant to the decision.
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Additional Review Notes
Add any other facts, observations, or follow-up items that should be preserved in the audit trail.
Filing Details and Audit Trail
This section preserves the filing metadata and reviewer trail needed to show what was submitted and when.
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FinCEN Filing Date
Date the SAR was filed or submitted to the filing system.
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FinCEN Acknowledgment Number
Acknowledgment or reference number returned after filing.
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Prepared By
Name of the person who prepared the filing.
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Reviewed By
Name of the supervisor or approver who reviewed the filing.
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Audit Trail Notes
Record any filing exceptions, corrections, or follow-up actions relevant to the compliance audit trail.
How to use this template
- 1. Enter the case reference, review date, reviewer name, and reviewer role so the worksheet is tied to a specific investigation and accountable owner.
- 2. Record the account type, activity date range, summary, indicators, and estimated transaction count using factual, date-specific entries rather than narrative guesses.
- 3. Select the SAR decision and write the rationale, then note the filing reason or escalation reason so the record explains why the case moved forward or closed.
- 4. Attach or reference supporting documents, related accounts, prior case history, and review notes so the reviewer can trace the evidence behind the conclusion.
- 5. If a SAR is filed, add the FinCEN filing date, acknowledgment number, preparer, reviewer, and audit trail notes immediately after submission.
Best practices
- Use a date picker for review and activity dates so the case timeline is consistent and easy to audit.
- Keep the activity summary factual and specific, and avoid vague labels like 'suspicious behavior' without describing the underlying indicators.
- Document why the case was escalated or not filed, not just the final decision, so the rationale is visible to a second reviewer.
- Reference supporting documents by file name or case ID instead of pasting unnecessary PII into the notes field.
- Capture related accounts and prior case history when the pattern spans multiple relationships or repeated events.
- Record the FinCEN acknowledgment number as soon as it is available so the filing trail is complete.
- Use conditional logic to show filing details only when a SAR is actually filed, which keeps the form shorter and easier to complete.
What this template typically catches
Issues teams running this template most often surface in practice:
Common use cases
Frequently asked questions
What is this SAR Decision and Filing Worksheet used for?
This template records the review of suspicious or anomalous account activity, the decision to file or not file a SAR, and the supporting rationale. It also preserves the filing details and audit trail so the case can be reconstructed later. Use it as the working record behind a FinCEN SAR decision, not as the SAR form itself.
When should this worksheet be completed?
Complete it as soon as a case is opened for suspicious activity review and update it again when the decision is made. If a filing is submitted, add the FinCEN acknowledgment details after submission. If the case is closed without filing, document the reason clearly so the record shows why no SAR was filed.
Who should fill out this template?
It is typically completed by a compliance analyst, AML investigator, fraud reviewer, or another designated reviewer with authority to assess suspicious activity. A supervisor or second reviewer can complete the review fields when your process requires escalation or dual approval. The template supports a clear separation between the preparer and reviewer.
Does this template replace the actual FinCEN SAR filing?
No. This worksheet supports the internal decision-making and documentation process, but it does not replace the official filing workflow. It helps you capture the facts, rationale, and audit trail that should align with the final SAR submission. The filing details section is for tracking the completed filing, not drafting the regulatory report itself.
What are the most important fields to complete accurately?
The case reference, activity dates, activity summary, indicators, decision rationale, and filing details are the core fields. Those entries explain what happened, why it mattered, and what action was taken. If your process includes escalation, the escalation reason and review notes should also be specific enough for later audit review.
How does this template help with audit readiness?
It creates a consistent audit trail showing who reviewed the case, what evidence was considered, what decision was made, and when any filing occurred. That makes it easier to respond to internal audit, compliance testing, or examiner questions. The worksheet also reduces gaps that can appear when decisions are tracked in email or scattered notes.
Can this worksheet be customized for different risk types?
Yes. You can tailor the activity indicators, evidence fields, and review notes to match fraud, structuring, money laundering, sanctions-related concerns, or other alert types. Keep the structure focused on the facts you actually use, and avoid adding fields that do not support the decision or the audit trail.
What common mistake does this template help prevent?
A common mistake is recording only the final decision without explaining the supporting rationale. Another is leaving out the activity window, related accounts, or prior case history that influenced the review. This template keeps those details together so the file shows both the conclusion and the reasoning behind it.
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