OP Here: ...you can see that viewed a certain way these transactions quite possibly are suspicious in line with the money being stolen. So while they lack deceptive "layering" there is obvious placement and integration, that is if you believe the money to be stolen in the first place.
1. Layering doesn't have to be deceptive in order to be layering. What do you mean, "deceptive?" Invisible? Hidden? Involving fraud or a lie? I'd say buying a truck with illicit proceeds of a crime, then selling that truck, then buying a jet pack then selling it, then putting the funds into a CD may be all "above board" but it can still be layering and money laundering.
2. Unfortunately for filing institutions and their customers, you don't have to "believe" the money to be stolen. The SAR is triggered if you suspect, or what's worse, if you "should suspect" that the money is illicit or derived from illicit activity or related to a crime. In other words, it's not important what you suspect; it's more important what your regulator will think you "should suspect."
3. Where there's smoke there's fire.
4. There is no penalty against the filer for filing a SAR. There may be one for failing to file it.
5. Anytime you have to spend this much time and effort debating it and agonizing over it and pondering it and losing sleep over it, my bet would be that it is SAR-worthy activity. If I'm "just not sure," I file it and let law enforcement sort it out.
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