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In Response To:
Thread Starter: Georgia Plum
Title: Re: Who do I file the SAR on?

Let's see, international debit card activity and structuring. How is he funding the debit card activity? Are his deposits into his account cash or wires or something else? I would probably file with two suspects, the maker and the payee. Your customer assisted in structuring these checks regardless of whether the payee asked him to or not.