Scenario: ABC Roofing maintains 2 business accounts. Bank recently discovered business licenses have been revoked.

What is the proper course of action? Insist the account be closed?

Please advise.

Thanks.

I would make an inquiry to the company and give them xx days to provide proof that they are again licensed prior to accepting additional transactions. This is not really a BSA/AML issue, more of a reputational risk avoidance practice now that you know.

I agree with rlcarey here - notify the customer to have them update the documentation. It's not directly a BSA compliance issue in 2016 unless you've exempted them, but it may be in 2018 when the CDD NPRM most likely goes into effect.

agreed with the above but will like to add

It's not directly a BSA compliance issue until the CMP show up.

Appreciate your input.