Currency Transaction Reports(CTRs) are strictly dollar-driven: if someone deposits/withdraws an amount over $10K in a single transaction, CTR is filed automatic

Currency Transaction Reports(CTRs) are strictly dollar-driven: if someone deposits/withdraws an amount over $10K in a single transaction, CTR is filed automatically. However, if you Zelle to X for a few times, and this X seems to receive too many Zelle payments, both you and X (assuming both have accounts at the same bank) can be reported through SARs with "this transaction has no apparent economic, business or lawful purpose." How banks figure out which transactions don't serve economic, business or lawful purpose? They can only figure out in a negative way. Either you should become a private banking client (in which case, you get a royal treatment through manual overrides, different compliance teams--just like first class vs economy class flights) or your banking routine should be four paystubs, 20 billpay, and debit card purchases. The more transactions (zelle, deposits, withdrawls, money orders, cashier checks) one is engaged in, the higher the chance that one will be SAR'ed though "transactions don't serve economic, business or lawful purpose".