We have a high-risk customer who has a long history of structuring. They also write a monthly check for their "rent" to a business entity for their store rent in the amount of $9,999.00.

My conclusion is that they are definitely structuring in some way.

My question is do I name both them and the business entity they are writing the checks to as suspects?

Thanks in advance!

I would name the high risk customer as a suspect and mention the lessor in the narrative.

Just curious...Why do you maintain an account relationship with a "high-risk customer who has a long history of structuring"?
I would have closed them out a long time ago.

I would list both as suspects versus just your customer and state in the narrative that you are listing both because you are not sure which individual initiated the structured transactions.

It could be that your customer has taken the initiative to write the checks in that manner, or it could be that the receiver / payee has asked for them in that manner. I can see where "Auditor247"'s point above, however, if your local SAR Task Force (assuming your area has one) is pulling all local SARs into a database and reviewing them, you would want the payee's name included in the search in case there are other SARs filed by other financial institutions.