I may have been answering a different question than what was asked, but it doesn't change my answer.
To determine whether we have a subject, we rely only on a name, no other PII.
To determine whether a non-customer payee of a wire or check or whatever is a subject or just another victim/money mule, unless we have a specific reason to believe that they are not the subject and therefore have not benefited or attempted to benefit from stolen funds, they're a subject. Being a money mule is illegal after all, whether wittingly or unwittingly. I agree that most of the time the beneficiary of these transactions is likely just another victim, but for our purposes I don't feel good just relying on likelihood.
If they're innocent, that should be law enforcement's job to sort out. Maybe it's just more SAR noise, but you may be providing some information that fits into a larger pattern that you can't see.