yes the new accounts person did an outstanding job of holding a casual conversation inquiring as to their business, the business, activities, and why they would come to us when there are clearly other banks where the business is located.
our OFAC search came up as FAILED. granted an FI doesn't have to deny an account opening based on that but it clearly was a red flag. they had their BSA policy in hand too. they indicated they had a 12 year relationship with their former bank but after a buy out were told they were no longer going to be banked. I feel they did have all their ducks in a row. we simply are not set up with personnel or resources to have handled this type of customer.
plan your Work and Work your Plan