If you have a business customer that you need to file a SAR on, who would you include as a subject on the SAR with the following example -
ABC Pizza DBA Kirk's Pizza Palace has structured cash deposits - the deposits are conducted by the delivery driver, not the owner.

Next Example -
You have a business customer that owns multiple entities that are included in the SAR with different partners on each entity, who would you include on the SAR and
Also who would you consider the High Risk customer? The business, the authorized signers/personnel, the business owner or all after the SAR is filed?

In the first example I would say that the owner is directing that the deposits be made in this manner, not the driver, so I would include the owner as suspect. For the second example we always include all authorized signers on business accounts as suspects when we are filing, although others may disagree with this approach.

I don't think there is enough information in your second scenario to arrive at a solid conclusion. Generally, I'll list business principals, and anyone else involved in directing the activity in question.

At my desk, being a signer on a business account does not automatically earn someone a subject entry. If that person a) did not participate in the activity, and b) did not direct the activity, that person does not get included in the SAR. It takes a some understanding of the business, how it works, and the roles different signers play, but this should all be part of the investigation anyway.

As paired, the two examples would represent an excellent case study for a BSA school. There is no direct answer for either and, as indicated by your first two responses, thoughtful consideration could yield different results.

The FinCEN SAR has recast the object of a SAR filing from being a "suspect" to a "subject." FinCEN did not explain the change, but field examiners acting on divine inspiration have had no problem attaching great weight to the new terminology, indicating that the "subject" is a more expansive term and is virtually all inclusive.

Road apples. The regulations requiring the SAR still refer to the "suspect."

While I see no value in including the name of the hourly employee who delivered the deposit or all signatories on the account, all I fear from the ambiguities of SAR filing is examiner fiat and being criticized for my failure to exercise judgment in the way he or she would have.

Include them all & assign their individual roles in the narrative. Let law enforcement sort them out.

Ken,
Excellent advice and insight. I appreciate it.
Love the use of the term 'road apples'. You are too kind. By the way, I shoveled a bunch of H P this past weekend at a Horse show. Funny, I didn't think of FinCEN when I was doing the duty.

Thank you for the input. One other question, in the second scenario, who would you consider the High Risk customer for EDD review on a SAR? The business, the authorized signers/personnel, the business owner or all after the SAR is filed?