I know you're not alone in disagreeing with our approach, so I'll add some support for people to consider as they're working it out for their programs.
I came to the decision to list all money mules as subjects based primarily on the FBI's money mule guidance, which states that "Acting as a money mule is illegal and punishable, even if you aren’t aware you’re committing a crime." https://www.fbi.gov/scams-and-safety/common-scams-and-crimes/money-mules
To my view, it's not my responsibility to determine whether or not they knew what they were doing, should have known what they were doing, or were complicit. It's a crime regardless. Doing this also make law enforcement aware of money mules, so that they can be tracked, contacted and dissuaded from laundering in the future. For example: https://www.justice.gov/opa/pr/us-l...-2300-money-mules-global-crackdown-money
Finally, it greatly simplifies our process when someone wants to debate what motivated our customer, or whether or not we should believe them when they say they didn't know what they were doing. If a criminal knew that to get out of their crime, all they have to do is tell the bank they didn't know what they were involved in, the most convincing criminals will never have a SAR filed. I often wonder when a new customer comes to our bank and immediately attempts to wire stolen funds overseas to their "fiancé" whether the bank that probably just kicked them out reported them or not.
The narrative will include an explanation regarding how the mule received instructions or met the criminal, as appropriate and applicable, and law enforcement can use that in their decision to pursue the case, or can disregard it entirely.