filing an amended SAR

Posted By: NotDoneYet

filing an amended SAR - 05/29/13 07:20 PM

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?
Posted By: NotDoneYet

Re: filing an amended SAR - 05/29/13 07:21 PM

I should add, I would include what of his info I do know to a Part 1 the next time I file.
Posted By: Elwood P. Dowd

Re: filing an amended SAR - 05/29/13 07:24 PM

While it's true that it's easier for law enforcement to search the narrative instead of the boxes, I do not see any basis for amending the SAR to move the information from one locale to another.

I assume this is all your auditor could find?
Posted By: NotDoneYet

Re: filing an amended SAR - 05/29/13 07:42 PM

It is all he found out of the dozen submitted.