One of our commercial customers receives and sends wires to a number of high risk jurisdictions such as Mexico, Guatemala and El Salvador, just to name a few. For the outgoing wires, we were able to identify the beneficiaries as operating within the complementary industries as our customer. However, the incoming wires are all coming through "JPMorgan Mexico Supply Chain" and, therefore, the true originator(s) is unknown. These incoming wires, however, do reference invoice numbers and appear to be commercial in nature.

That being noted, is it suffice to deem the activity as not suspicious, or is a SAR warranted at this point? While I'm on the fence of filing, a third-party's point of view would be helpful.

What are you told when you ask for the true originating party information?

Have you asked the customer about the incoming wires? Trying to guess without at least asking the question is simply not an option. If you customer is legit and the wires are legit, your customer should not have a problem providing the information.

^ Exactly. Ask the Customer about what is going on. You may even be able to obtain some documentation to back up their claims.

We have attempted to reach out to the customer to no avail. Since we don't have the luxury of waiting for a decent response, I guess filing would be the safer approach at this time around.
Thank you all for the input!

So, do you plan to continue accepting those sorts of wires for this customer in the future?

Unless there is more to the fact situation, I'm not sure why you would come down on the side of filing. All of the facts you've gathered so far and presented here, you've said, are indicators of legitimate business.

If you're not able to make contact with the customer (that's how I read your "attempted to reach out" statement), you might consider a 314(b) call to the originating bank.

Is this the originator?

I am not seeing the need for a SAR based on what you have described.

Does the above link help you?

I see no basis for a SAR based on the wires. However, the customer's unresponsiveness to repeated requests for information or documentation; e.g. copies of the invoices when requested, might be more than enough to get your juices flowing.

You need a sit down with the customer.

If the customer has a borrowing relationship with your bank, I suggest you sit down with the lender of record first to explain your concerns and perhaps glean some additional information the help flesh out the picture for you. If a sit-down with the customer is needed, it could be more productive (depending on the personalities involved) to include the lender in the conversation. Customers often take a more consultative stance with lenders that with operations types, and they can be put off by someone wearing a BSA/AML hat.