I recently posted regarding something similar that came up in our Feb. exam. Our FDIC examiner, considered to be the BSA expert for our state, has told us anytime an individual conducts a large cash transaction, large enough for CTR filing, we should file a SAR on it unless we can come up with a good explanation for their activity. They are emphasizing "unusual" should be viewed as suspicious. Based on this mandate, we have already filed hundreds of SARS (literally) this year. Enough to warrant a full time SAR filer for our less than $5b institution.
Possums sleep in the middle of the road with their feet in the air.