Writing a reason that survives an audit
The reason is read months later by somebody who was not there and cannot ask you anything. Write it for that reader rather than for the colleague sitting next to you.
A reason is the sentence or two you record alongside an outcome, saying what you concluded and what it rests on. It is the single most read thing you write on a case, and the only part a reviewer is certain to read.
The reader is not a colleague. It is somebody eighteen months from now, possibly a regulator, who was not there, does not know the customer and cannot ask you a question. Everything below follows from that.
What a reason has to do
- Say what you concluded
In plain words, not as a label. "The activity has an explanation" rather than "closed, FP".
- Say what it rests on
Name the two or three findings that carried the decision. Not all of them, the ones that mattered.
- Say what you ruled out
A reader needs to know you considered the other reading. One clause is enough.
- Stand on its own
Readable without opening anything else. A reason that only makes sense beside the findings has moved the work onto the reader.
The false positive is the hard one
Closing a case because nothing was found is weak. Closing it because you found the explanation is strong, and they look similar at the moment you write them.
| Weak | Strong |
|---|---|
| No evidence of suspicious activity. | The nine transfers are supplier payments to a declared counterparty in Singapore, matching invoices the customer supplied on 8 October. |
| Customer is long-standing and low risk. | The amounts and the corridor match the customer’s declared purpose on file since onboarding in 2021, and the pattern is consistent with the previous eleven months. |
| Screening returned no matches. | OFAC, EU and UN returned no match on 7 October. DFAT did not answer and was re-screened clean on 9 October. |
Four ways a reason fails
- It states an inference as a fact
"The customer was avoiding the threshold" asserts something the chain cannot show. Describe the pattern and let it carry the weight.
- It cites a number with no source
"High exposure" and "scored 82" are both uncheckable later. Name the vendor, the figure and the date.
- It uses shorthand the reader does not have
Internal abbreviations, a queue name, a colleague’s initials. All of it is unavailable to the person reading it in 2028.
- It describes the process instead of the conclusion
"Reviewed and discussed with the team" says what happened to the case, not what you decided or why.
What this changes
A decision that was reasonable on the information available at the time is defensible even if it later proves wrong. That defence exists only where the record shows what you knew and when you knew it. The reason is where you say it, so write it while the case is in front of you rather than reconstructing it afterwards.
Related
Last checked against the product on .