I am preparing to file a SAR on a fraudulent ACH debit transaction file that was received by the bank. We did not process the file. My question is do I include the names of the "payroll recipients" as suspects in the SAR, or should I just name them in the narrative along with the beneficiary bank, account number and dollar amount?

Any other tips for filing a SAR for this type of activity are appreciated. This is a new one for me.

Why not dump it all into an attachment file.

That's a good idea; however, I just joined this bank and apparently they have been criticized in the past for not reporting all suspects in a SAR.

Do you really even have a suspect that you can identify?

The only names we have are the recipients of the ACH transactions. There are over a dozen of them at different banks.

Should I be checking anything in Item 40 for this? For example, c. Funds Transfer?