When these P2P app transactions appear reasonable in the context of the customer and their account, I don't see a problem. But when the customer is already tagged as higher-risk from a BSA/AML perspective and you see unexplained, high-value P2P transfers in and/or out, I think you would smell a SAR in the making.
A low balance account that gets unexplained larger value deposits and transfers out those amounts via P2P, effectively churning funds through the account rapidly, would also deserve some attention.
As mentioned earlier, a conversation with the account holder may clarify matters for you and give the transfers some legitimacy. But if you can't develop a reasonable explanation for the activity .....
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8