If we have a customer that we are reasonably sure is structuring and have placed them in our High Risk customer program, is it in violation to retain the account if we continue to file SARs on them?

If it is a violation, then how long do you have to close out the account after the detection of the activity? and what is the fine?

Prior thread.

You are not required to close the account, hence, there is no fine for failing to do so. The regulators do not give even broad direction regarding account closure, but individual examiners oftentimes have no qualms about telling the bank what it should have done.

If you are certain they are only structuring, they are still imposing a significant burden on your bank; i.e. at some point it's a cost issue, not a legal issue as to whether you continue to monitor, research and file SAR after SAR.

Yes, individual examiners will have an opinion about customer accounts that are kept open. But you need to check your deposit agreement to make sure you have allowed for closing an account a the bank's option.

As stated, it is not a violation but you are creating work for the bank. You must constantly check to see that they are doing nothing else and you have the continuous monitoring and reporting. You will have a growing number of clients to monitor if you allow them to remain with your bank.

We have taken the position that it is too expensive and too risky (why are they structuring...are they hiding income? Why?). We try to stick to a 3 strikes and you are out policy. If it is a good customer with high balances we counsel them and give them another chance.