State examiners are notorious for providing terrible BSA/AML related advice. When was the last time you saw someone written up in a report for filing too many SARs? I'm not suggesting you file defensively. I'm suggesting in cases such as this, there is no legitimate business reason for such transactions that could ever be explained even if you asked the customer. The customer of course would make something up. I see more time wasted by banks on these one-off issues, such as discussions, more research, arguments in SAR committees, etc. All that does is cost the bank even more money. File and be done with it.
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