Disregard the fact that your regulators made no comment; it proves nothing.
As you say, these were two separate incidents with one structuring cash in and another structuring cash out. Continuing SARs are about an uninterrupted stream of similar activity, not just the fact that the same subject was involved.
Tell your auditor that you disagree and ask for documentation of his or her position. If you want to hold the trump card before the conversation begins, call the FinCEN Helpline and see what they say first. Make it plain this is not a hypothetical; i.e. both SARs were filed and you are being told the second should be amended.
P.S. For future reference, any time a SAR lists a subject that has been the subject of a previous SAR it would be prudent to mention the prior filing and provide the DCN. That does not make it a continuing SAR nor is that the basis for filing an amendment. It's just an attempt to be helpful to law enforcement.
Last edited by Ken_Pegasus; 06/09/15 07:45 PM. Reason: Add P.S.
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.