We are filing a SAR on a corporation so they obviously are a suspect. Do we need to complete additional suspect info for the business owners or just list them in the narrative? We have some info on the owners but not all.

I would list the owners - since they are the ones doing the transactions ...

if you don't know a section - just put "unknown".

Any individuals that conducted the transactions (whether or not they are owners of the company) in question should be listed as suspects.

"Any individuals that conducted the transactions (whether or not they are owners of the company) in question should be listed as suspects."

Why is that. Unless you believe that they were complicit, why would you list the transactors? Owners, yes. Some poor shmuck that is running the deposits to the bank - why would you do that without cause???

Good point Randy- my choice of words was poor. The individuals that are responsible for the transactions, of course, are not always the same people we see in front of us.

But likewise, I wouldn't be willing to assume that all of the owners are complicit, either, and that was the point I was aiming for.

Anytime we complete a SAR we include the title of the account and all signers including their personal information. If there is another person involved (such as an employee) we would not report them unless something they did was suspicious; such as refusing to provide identification when making a cash deposit over $10,000