Random thoughts --
For a small bank, a deposit account of that magnitude could easily throw the bank's asset/liability management into a tailspin. It reduces your loan/deposit ratio but you'd probably only be able to put on short-term loans because you're looking at hot money.
The description of the account and its likely activity sounds like something you would have to do some heavy EDD on. The potential for money laundering is huge, and you really need to know the depositor really well, as well as the sources and destinations of the wires. OFAC checking will be an absolute must.
Will you have to put on added staff and/or hours of operation for your "wire room" facilities to accommodate this customer?
Do you have any information on the lifespan of the relationship? Will you be gearing up only to have it run its course in several months?
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8