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#2035992 - 08/27/15 04:42 PM References to DCNs for Amended SARs
New Manager Offline
100 Club
Joined: Jan 2004
Posts: 136
We're doing a 90day review for a SAR filing and will re-file. Since the last re-file we've had to several amendments (identification info for the business was not completed on any of their 3 filings so we had to amend all three SARs over the last month). When referencing in the narrative the DCNs for those previous filings, do we mention the old DCNs, the fact that we amended, and then list the new DCNs? Or do we just list the new DCNs and omit any mention of the amendments?

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#2036028 - 08/27/15 05:40 PM Re: References to DCNs for Amended SARs New Manager
EB, CAMS Offline
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EB, CAMS
Joined: Mar 2009
Posts: 133
flyover country
If it was me, I would list the amended DCNs only. No need to further confuse potential law enforcement reading the narrative. Give them the DCN for the previous SAR you want them to read (that is complete and accurate).
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#2036065 - 08/27/15 07:26 PM Re: References to DCNs for Amended SARs New Manager
New Manager Offline
100 Club
Joined: Jan 2004
Posts: 136
Actually my coworker called FinCEN, not knowing I was posting here, and they said to like the old DCN, the fact that it was amended, and then the new DCN number.

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#2036210 - 08/28/15 02:19 PM Re: References to DCNs for Amended SARs New Manager
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Probably not a great idea to question the response of people who should really know the answer, but that makes absolutely no sense at all. An amended SAR is the complete document. There is no need to reference the original or any intervening amendments. I'm pretty sure whoever you spoke with just made that up. wink
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