Our customer was convinced by an online boyfriend to allow money to be wired to her account; then take the cash to a different company to wire it to a 3rd party. When completing the SAR, is our customer a suspect?

Generally, my default position is they are suspects. I can be convinced otherwise sometimes, depending on the situation.

I would say yes, put the facts in the narrative, and let law enforcement determine if he/she truly is.

In some of these scenarios the bank's customer is the intended victim, not the suspect. I don't think that's true in your example.

They put all of those little boxes on the SAR and yet there isn't one for "incredibly stupid."

Thank-you, so much, for your help. I totally agree with the 'totally stupid' part!

Remember, for the purposes of the form, they are a subject , not a suspect. You would only need to omit them from the form (not necessarily the narrative) if you truly considered them a victim. IMHO, it's best to err on the side of calling them "subjects."

The current report says "subject." The regulation still says "suspect."

Per the SAR Instructions:

"Part I Subject Information: Complete a Part I section on each known subject involved in the suspicious activity. [b]Persons who are victims of the suspicious activity are not subjects and should not be recorded in a Part I section. Victim information, if necessary for a complete description of the suspicious activity, should be recorded in Part V."