From Detection to Submission: The art and style of a well-written SAR-Suspicious Activity Report

Course Overview 

In an interconnected globalized economy, managing money laundering, terrorism financing, and sanctions risks is a top priority for organizations in order to avoid monetary penalties and reputational harm. First and foremost in any AML/CFT program is the filing of reliable SARs with the regulator (FIU) as soon as suspicious activity or a red flag is detected. Given the importance of preparing and filing quality SARs and their usefulness in describing information about specific irregular activity for possible law enforcement investigation and prosecution, this course will uncover the main components of a SAR and the investigation-driven data it must contain from the outset until the report is submitted.

Learning Outcomes

By the end of the programme, participants will be able to:

• Gain practical insights on AFC techniques and how to detect KYC, UBO, screening, & transactions anomalies leading to suspicion
• Conduct a coherent investigation process which is foundational for effective reporting of quality SAR
• Navigate the SAR journey properly and vigilantly in line with FIU expectations
• Implement freezing orders and manage blocked accounts and assets in accordance with best practices and international standards
• Understand the depth and breadth of the 5 W’S featured in SAR narrative

Training Outline 

SAR reporting:

• What constitutes good reporting or bad reporting

• Importance of financial leads for the regulator

• Components of the international regulatory compliance framework

• Evidence vs indicator-based SARs

Foundations of AML/CFT and sanctions programs:

• Reporting entities: Banks, Non-Bank Financial Institutions, & Designated Non-Financial Businesses and Professions (DNFBPs)
• Modus operandi of UBO identification in complex ownership structures
• Divestment or Sham investment as a sanctions evasion technique requiring SAR filing
• Traceable accounts as an EDD measure for high risk profiles
• Compliance with UNSCRs, OFAC, & EU sanctions and other autonomous regimes
• Disclosure of SAR information and statistics to your correspondents: option or obligation!

Dealing with Suspicious indicators:

• The specifics of SARs related to Anti-bribery and corruption indicators and PEP exposure
• Operationalization of “attempted” vs “completed transactions”
• Scope of “Reasonable grounds to suspect” and “reason to know”
• Core Elements of the investigation process
• Reaching out to clients for supporting documents while adhering to “tipping off” principle (FATF R 21)

Post SAR filing actions and duties:

• FIU feedback and methodology in coming back to REs whether suspicion materializes or not
• Implementing freezing/blocking orders
• EDD to be practiced on blocked accounts with effective internal controls to protect financial integrity

Establishing Whistleblowing mechanism to bolster SAR reporting:

• Components and management of whistleblowing system
• The Buy-in from BODs and incident reporting to the concerned board committees

Industry Expert | Shawki G. Ahwash- CAMS,CGSS

Shawki brings under his belt 20+ years of banking experience spanning multiple areas like cross-border payments and investigations, trade finance, customer onboarding and KYC operations, correspondent banking, and last but not least AML/CFT & sanctions compliance. In his compliance function, he assumed Money Laundering Reporting Officer (MLRO) and Chief Compliance Officer (CCO) functions and responsibilities for 10 years within Lebanese banking sector.

In parallel, Shawki is a University lecturer, speaker, and trainer at: Union of Arab Banks (UAB), ACAMS, Romanian Banking Institute (RBI-Bucharest), OECD/Paris, Governance Dynamics (UAE), General Council for Islamic Banks and Financial Institutions (CIBAFI)-Bahrain, Emirates Institute of Finance (EIF-UAE), and other organizations tasked with countering money laundering, terrorist financing, sanctions evasion, & proliferation finance. Moreover, he is an adjunct trainer at PwC’s academy in Dubai & have been contracted as subject matter expert with other big 4 consultancy firms in London and KSA to render AFC services in different aspects.

As an ACAMS Certified Anti-Money Laundering Specialist (CAMS) and Certified Global Sanctions Specialist (CGSS), he has designed and delivered a diverse array of training programs addressing sanctions due diligence, AML/CFT threats, TBML, & ABC-Anti-Bribery & Corruption in MENA, GCC, and Europe. Also during his engagements as SME in consultancy projects in East Africa, Shawki had contributed to building & strengthening AFC capacities of FIUs and other competent authorities.

Among his other certifications, Shawki holds Combating Financial Crime (CFC) certificate from Chartered Institute for Securities & Investment (CISI)-UK and teach their course throughout the region. On the academic level, he holds a Master’s degree from American University of Beirut (AUB) in Public Administration.

Who Should Attend 

The programme is ideal for:

• C-Level Executives and Senior Managers in Investment Firms
• Compliance Officers
• Operations department (transfers, branch managers, trade finance)
• Customer service
• Risk officers
• RMs & Mid-management in Financial Institutions departments
• Government agencies and law enforcement
• Supply chain and procurement managers
• Internal Auditors
• Internal Lawyers
• External Auditors, Lawyers and Financial Consultants