A suspicious activity report drafting checklist sets out what a good draft must contain, who is involved, what happened, when, where, how, and above all why it is suspicious, and what the reviewing officer checks before anything is filed. An AI agent can draft against the checklist. The nominated officer decides whether to file, and files.
What makes a suspicious activity report useful?
A suspicious activity report goes to the authority that receives financial intelligence in your market. Its value depends on being readable by someone with no access to your systems: clear subjects, clear facts, and a stated reason for suspicion. A long narrative that lists transactions without saying what is suspicious about them is of little use. The FATF Recommendations set the international standard for reporting suspicious transactions; your local law sets the form, the authority and the deadlines.
The checklist makes each draft complete and consistent. It also makes review faster, because the officer checks against known fields instead of reading for gaps.
Where does the agent fit?
Drafting is a good use of an agent. It can assemble the investigation file, list subjects with their identifiers, build the transaction timeline and turn the analyst's findings into a structured narrative. That is depth 2 work, held for a person. The process is in how to draft suspicious activity reports for review with an AI agent.
Filing is not. The decision to report rests with a named person under the law in most markets, and the consequences of filing or not filing fall on that person and the firm. An agent can draft a suspicious activity report but never file one makes the argument, and whether an AI agent can file a suspicious activity report answers the question directly.
How do you use the checklist?
The agent drafts the report and completes the checklist, marking each item as present, absent or not applicable. The reviewing officer works through the same checklist, edits the draft, decides and signs. Each item should be checkable from the draft itself.
Two items matter most. Grounds for suspicion must be explicit: what about the activity is inconsistent with what you know of the customer. Tipping off must be considered: the agent must not have sent, and must not send, anything to the customer that could alert them, and any customer-facing activity on the case must be held.
The suspicious activity report drafting checklist
| No. | Item | Present? |
|---|---|---|
| 1 | Reporter details and internal reference | |
| 2 | Each subject: full name, date of birth or registration, address, identifiers | |
| 3 | Accounts involved, with numbers and dates opened | |
| 4 | What happened: transactions with dates, amounts, counterparties | |
| 5 | How: the method or pattern, in plain words | |
| 6 | Where: locations, countries, channels | |
| 7 | Grounds for suspicion: why the activity is inconsistent with what is known | |
| 8 | What the customer said, if anything, marked as their account | |
| 9 | Linked parties and their role | |
| 10 | References to earlier reports on the same subjects | |
| 11 | Actions taken: restrictions, exits, consent requests where your regime has them | |
| 12 | No speculation beyond the evidence; no internal jargon | |
| 13 | Tipping off: no customer contact that could alert the subject | |
| 14 | Officer's decision: file or not file, with reasons | |
| 15 | Filed by, date, authority reference |
A filled example
A hypothetical bank's investigation concerns a small business account receiving cash deposits.
| No. | Agent's draft | Officer's review |
|---|---|---|
| 2 | Business and its sole director, with identifiers | Accepted |
| 4 | 38 cash deposits over eight weeks, each between 900 and 990, at 11 branches | Accepted |
| 5 | Deposits just under the branch reporting threshold, spread across branches | Accepted |
| 7 | "Turnover far exceeds the declared level for a small cleaning business; pattern suggests deliberate avoidance of thresholds" | Edited: added that the business's card receipts fell over the same period, so cash replaced rather than added to income |
| 8 | Director told a branch colleague the cash came from "new contracts" (declared) | Accepted |
| 10 | None found | Officer checked separately; one earlier report found under a former company name; added |
| 13 | Customer-facing agent's queued message about the account review was held | Confirmed held |
| 14 | File: grounds met |
Item 10 shows why the officer reviews more than the narrative. The earlier report sat under a different company name the agent had not linked. Item 13 shows the hold doing its job: a routine message would have alerted the customer.
Where Pryme fits
In Pryme, report drafting runs at depth 2, and filing is held for the named officer; no agent at any depth sends a report to the authority. Customer-facing actions on a case under investigation can be held across all agents. Concerns raised by staff follow a separate route; see whether an AI agent can handle a whistleblowing report. The boundary is in AI compliance agents: second line, never the last word.
Questions people ask
Should the agent decide whether activity is suspicious?
No. It can set out facts and patterns and show where they depart from the customer's profile. Suspicion is a judgement made by the analyst and the officer.
Can the agent draft a "not filed" rationale too?
Yes, using the same file. The officer's reasons for not filing are as important to record as the reasons for filing.
How should drafts be kept?
Keep the agent's draft, the officer's edits and the final report together, with restricted access. They show how the decision was reached.