Sister, Husband and Wife scenario: Two owners of a business are unquestionably involved in structuring. That part I know for sure. Currency slightly below the CTR reporting level is being deposited into Husband's account, Husband owns a business. Sister isn't on the account, but she's the conductor, and also an owner of the same business as Brother. I don't have anything to know that the wife was involved other than that on a CTR, the wife benefits from deposits, and is included. According to what the conductor told the teller, Husband directed Sister to deposit the currency from the business into his personal account to pay bills.

I'm inclined to say no because wives don't always know what their Husbands are up to, but to play it safe I wanted to ask you all. Should Wife be included on the SAR?

If Wife is not directing or participating in the activity, I am inclined to not list her as a subject- particularly if she has no affiliation with the business account. However, I would mention her relationship to the account(s) in the narrative.

Thank you. You confirmed what I was thinking. There's nothing to show that she had any part in the transactions.