I have a business customer who owns a roofing company who has made multiple cash withdrawals at $10K+. It's $10K or so once per week. We're doing our CTR filings. When she's asked about the purpose of the cash withdrawals, she says its for payroll. Payroll in cash for a roofing company. My question is how do I know if she's paying the proper payroll taxes by paying her employees in cash without directly asking her? Also, is this SAR worthy?
I feel like it is SAR worthy but what's holding me back is that I don't have any way to know if she's paying the proper payroll taxes. I don't want to file if she's doing everything right. But SAR filings are about reporting suspicious activity even if you don't know if there's criminal activity behind it.