An employee discovered a news article on a former customer that was being indicted for a money laundering offense (no time period given). The individual had an acct with our financial institution - but the acct has been closed for nearly 6 years. Is there a standard or acceptable period of time that if an acct has been closed for said period, the bank is not required to go back and investigate transactions from when it was open? Is anyone aware of any FinCEN or other Regulatory guidance on this issue? I combed through the "Tips N Trends" and couldn't find any.

The only time we would do this is if we receive a subponea for records.

If there is a requirement, I would like to know as well.

Considering that the record retention period for BSA is 5 years, I don't see how you would be expected to review activity that is older than that.

Actually, there is no written standard that says you are required to look at your existing accounts when your customer makes headlines. It just falls under the heading of enhanced due diligence. Personal opinion only, the fact the account is closed or has even been closed for a long time would not affect my curiosity, but it would definitely affect the amount of time I would spend investigating.