Skip to content
BOL Conferences
Thread Options
#2250500 - 03/12/21 08:15 PM Attach spreadsheet to amended SAR?
Compliance Nut Offline
Member
Joined: Mar 2007
Posts: 88
We need to file an amendment to a SAR due to an error the filer made in item 24 Relationship of subject to institution. I have updated the original narrative with a beginning sentence explaining the amendment and correction. My question is, when I file the amendment should I attached the spreadsheet that was included in the original filing?

Return to Top
BSA/AML/CIP/OFAC Forum
#2250794 - 03/18/21 12:16 PM Re: Attach spreadsheet to amended SAR? Compliance Nut
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,662
I've not seen anything affirmatively address spreadsheets specifically, but this is from FinCEN's SAR FAQs:
"The filer should complete the FinCEN SAR in its entirety, including the corrected/amended information and noting those corrections at the beginning of the narrative, save (and print, if desired) a copy of the filing, and submit the filing."
_________________________
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

Return to Top
#2250807 - 03/18/21 02:19 PM Re: Attach spreadsheet to amended SAR? Compliance Nut
Compliance Nut Offline
Member
Joined: Mar 2007
Posts: 88
Yes and in my mind that would include attaching the spreadsheet, but our internal audit says it does not.

Return to Top
#2250811 - 03/18/21 02:30 PM Re: Attach spreadsheet to amended SAR? Compliance Nut
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,662
Are they saying it is a problem to include the spreadsheet? Do they have a citation?
_________________________
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

Return to Top
#2250813 - 03/18/21 02:40 PM Re: Attach spreadsheet to amended SAR? Compliance Nut
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
If you leave off the spreadsheet, then it will no longer show in the amended record I believe. As Adam said, the spreadsheet is part of the SAR "in its entirety". It totally replaces the original.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top

Moderator:  Andy_Z