However, the Exam Manual does not indicate whether or not a suspect must be known when it states, "Transactions conducted or attempted by, at, or through the bank (or an affiliate) and aggregating $5,000 or more, if the bank or affiliate knows, suspects, or has reason to suspect that the transaction:
*May involve potential money laundering or other illegal activity (e.g., terrorism financing)..."
Does it have to do with where the suspicious activity occurred, i.e., "by, at, or through the bank" or elsewhere?