Skip to content
BOL Conferences
Thread Options
#1990614 - 01/23/15 03:10 PM Requesting account to be closed
Calmeida12 Offline
100 Club
Joined: Sep 2012
Posts: 249
When requesting to get an account closed due to the # of SARs and the type of activity running through the account. What do you tell the Account Officer as they want a reason to tell the customer? Thank you.

Return to Top
BSA/AML/CIP/OFAC Forum
#1990617 - 01/23/15 03:23 PM Re: Requesting account to be closed Calmeida12
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,364
Galveston, TX
We are exercising our right to close your account at any time per our depositor's agreement, paragraph XX.

You don't owe them an explanation.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#1990618 - 01/23/15 03:26 PM Re: Requesting account to be closed Calmeida12
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Surely the account officer already knows that the customer's engaged in activity that has prompted enhanced due diligence (translate it for the account officer as "extra work and costs" if the concept of due diligence is foreign to him or her). That's really all the account officer needs to know, particularly if he or she is not aware that SARs are being filed (you shouldn't share that information with the account officer).

As for what the account officer tells the customer, the less said, the better. There is no legal obligation to provide a reason; any desire to share a reason with the customer should be satisfied with "We have decided not to continue doing business with you."
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#1990669 - 01/23/15 05:01 PM Re: Requesting account to be closed Calmeida12
Calmeida12 Offline
100 Club
Joined: Sep 2012
Posts: 249
Also, should we just close the account in question or all their other business relationships where nothing is going on?

Return to Top
#1990676 - 01/23/15 05:14 PM Re: Requesting account to be closed Calmeida12
ACBbank Offline
Power Poster
ACBbank
Joined: Jul 2006
Posts: 4,348
New York City
^ Are the associated accounts involved in the activity which prompted the first account to be closed? Are the associated accounts profitable?
_________________________
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

Return to Top
#1990728 - 01/23/15 06:50 PM Re: Requesting account to be closed Calmeida12
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top
#1990829 - 01/23/15 09:34 PM Re: Requesting account to be closed Calmeida12
HappyGilmore Offline
10K Club
Joined: Jun 2004
Posts: 19,855
Pulling people out of the ditc...
Originally Posted By: Calmeida12
Also, should we just close the account in question or all their other business relationships where nothing is going on?


if I have 3 accounts at your bank, you close one me, I guarantee i'll be closing the other 2 if you don't close them as well...and moving any loans...closing credit cards...

which, ultimately, you as a bank would want.
_________________________
Providing alternative truths since the invention of time

Return to Top
#1990871 - 01/24/15 04:08 PM Re: Requesting account to be closed Calmeida12
Cape Codder Offline
Gold Star
Joined: Jul 2011
Posts: 413
Originally Posted By: Calmeida12
Also, should we just close the account in question or all their other business relationships where nothing is going on?

If you don't close the entire relationship you run the risk that the suspicious activity just transfers to the remaining accounts (have had that experience). Close everything, and save yourself some future headaches.
_________________________
Nothing difficult is ever easy.

Return to Top
#1991337 - 01/27/15 04:46 PM Re: Requesting account to be closed Calmeida12
ComplianceGurl, CRCM Offline
Platinum Poster
Joined: Jul 2007
Posts: 500
I tell them it was just a "business decision". They don't like it and I usually have to repeat it several times. :-)
Last edited by ComplianceGurl; 01/27/15 04:47 PM.
Return to Top
#1991431 - 01/27/15 06:51 PM Re: Requesting account to be closed Calmeida12
NU Rhules Offline
Gold Star
NU Rhules
Joined: Mar 2011
Posts: 473
SE, Nebraska
If you run into resistance it's because they don't respect (or understand) your position. Perhaps it would be best to have his/her supervisor give the direction to close the account. Every bank handles it differently I suppose.

Return to Top

Moderator:  Andy_Z