The Tennessee Division of Business Services states that an administratively dissolved corporation continues its corporate existence but may not carry on any business except that which is necessary to liquidate its business, close operations, and notify claimants. If we have a corporate business customer whose entity status is "Dissolved/Revocated", based on a search of the Secretary of States' website, should we ask this customer to furnish new CIP documentation regarding their current business entity status and, if the customer fails to support the business structure and account titling appropriately, should the bank consider account closure? Should the bank also consider filing a Suspicious Activity Report?

Depending on the type of account relationship and whether or not you believe they are doing more than "any business except that which is necessary to liquidate its business, close operations, and notify claimants", I would be requesting an explanation. Closing the account would be up to bank management. I don't see a SAR entering into the picture, unless something else was going on.

What if the business is currently exempt from currency transaction reporting? Would you revoke the exemption and begin filing CTRs again?

Yes, most definitely. Although, if the business is liquidating, it's unlikely to be generating much in the way of cash transactions.

One last question...and I've asked this one many times at different venues and received different answers. If the entity has been administratively dissolved solely as a result of not having filed the annual report and paid the fee, should we decline to establish a new account?

Yes.

There's an echo in here: Yes.

It's nerve wracking to have an existing contract with an entity that's failing to do the things necessary to maintain it's existence.

It's something entirely different to assume you can enter into a new contract with an entity that is officially deceased. All that fine print in the agreements you got them to sign?

It doesn't mean a thing. They don't exist.

Thank you both. There's truly a smile on my face!