Our external auditor believes I should file an amended SAR on an ongoing situation(since 2011)because I did not complete a Part 1 subject information on a non-customer involved in the suspicious activity. I know his name and profession, which is included in the narrative, but nothing else.
In the directions for completing a SAR, page 83, it states: "An amended report must be filed on a previously-filed FinCEN SAR or prior SAR versions whenever new data about a reported suspicious activity is discovered and circumstances will not justify filing a continuing report."
I don't have any new data to give, but he wants this guy's name and occupation on the subject info page.
I'll probably just do it, but does it sound like I really need to to anyone else?