1. Strong Investigations and Suspicious Activity Reports: Understanding the Triangle

Strong Investigations and Suspicious Activity Reports: Understanding the Triangle

Strong Investigations and Suspicious Activity Reports: Understanding the Triangle
Event ID: 70902
Not for Sale
Recording: 13808

Duration: 90 minutes including question and answer session.
Presenter(s): Kenneth Agle, president, AdvisX
$299.00, On-Demand includes full audio presentation, question and answer session, and presentation slides.
Who Should Attend? BSA officers, BSA personnel, compliance officers, internal auditors, risk officers, operations personnel, front line personnel


The exact requirements for completing an investigation are generally undefined by definition. After all, there is no one fit solution that can accommodate the vast array of nuances associated with suspicious activity. Essentially, the onus is placed on the organization to establish investigation and SAR narrative sufficiency. However, while there may not be exact requirements, there are exact principles that can and should be applied. Applying these principles is about understanding triangles of investigation such as (1) what we expected, (2) what we found and (3) what differences were exhibited that give rise to investigation and potential SAR filing.

Financial institutions must have employees that are familiar with the answers to this and other related triangles. Moreover, when investigations fail, it is often a byproduct of failed foundational elements needed to properly complete the triangle. For example, weak CIP and CDD will expose an organization in answering the first question because that organization never established this element. No investigational skills can resolve such gaps, but allow organizations needed emphasis to close those gaps as soon as practical. Moreover, a weak monitoring system leaves the organization’s second leg of the triangle in jeopardy of failure and again, this is often outside of an investigator’s domain. But, when these first two angles are established, it is on the investigator to close the third and this requires perhaps the most skills.

This webinar is about presenting the need for all three angles. It provides a basis for how CIP/CDD and EDD flow into the investigation. How monitoring through automated and manual systems provides a critical element to the investigator and then how the investigator uses those elements to build on a complete investigation. This webinar focuses on meaningful elements needed to complete the investigation and a tool for evaluating from a quality control perspective the strength of the investigation and potential SAR submission. While no QC can or should provide 100% coverage, it should utilize tools aimed at providing meaningful feedback to the investigator that promotes education and improvement. With this knowledge, an institution can expect its personnel to more effectively complete robust investigations and craft powerful suspicious activity narratives.

Please join Ken Agle, president of AdvisX, as he guides you through the investigation triangle and how the principle of the triangle is fundamental to sound BSA/AML program compliance.


Join this webinar to learn:

  • Guidance on completing Suspicious Activity Reports and an overview of the most common problems associated with SAR completion
  • The foundational angle of CIP/CDD/EDD and how it must be used to complete investigations
  • The critical angle of monitoring and detecting and how understanding this foundational angle guides a sound investigation process
  • Techniques and processes to follow to ensure that your investigation of suspicious activity is incorporating key aspects from the first two angles in completing the triangle
  • Using a simple, but effective Quality Control Investigation tool that evaluates the strength of the investigation using a series of rated factors to score and guide current and future investigations



Your conference leader for "Strong Investigations and SARs: Understanding the Triangle” is Kenneth Agle. As president of AdvisX, Mr. Agle brings over 30 years of financial institution regulatory and regulatory response experience covering numerous facets of financial institution operations. Mr. Agle specializes in strategic regulatory response and in developing and implementing both proactive and reactive tools and systems to preempt and resolve issues affecting today’s financial institution. Prior to his consulting experience, Mr. Agle had been a financial institution examiner with the FDIC. As a commissioned examiner, Mr. Agle was principally involved in numerous examinations, including safety and soundness, compliance, BSA, IT and fair lending.


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BankersWEB certificates of participation are available to everyone completing this webinar.