Good morning,
We have a long time commercial customer who runs a cash intensive lucrative business that has always kept business local. Recently, they have begun sending wires to Romania so naturally I questioned the PB who submitted the request as to the purpose. The PB was unsure so she called the business customer and the business customers reply was one of the business owners (not on the account and opened before BO was a thing) is living in Romania and looking to start an additional business in that area, same line of business. As time went on another wire was sent and the purpose given originally had changed a bit and put up a few red flags. Management decided we are going to send the customer a certified letter asking due diligence questions but the part we are stuck on is who should this letter come from? I've always been told it shouldn't come from the BSA Department directly. We are a small community bank so we don't have many departments but we have a wire department, a BSA department, branch managers and a retail banking officer. Our idea currently is to have the letter come from the wire department but one of our managers wants it to come from a specific person. Any thoughts or insight would be super helpful! Thank you.

Who the letter comes from is up to the Bank. Our process is our RMs are responsible for reaching out to clients and getting written responses and documentation requested by the BSA Department. It's their customer after all and they are responsible for knowing this type of stuff. I'm surprised your RM didn't know. With out RMs if money starts leaving our shop they are all over it as it effects their comp.

I, as the BSA Officer, would only get involved if it was something serious or complex was observed. It's been my experience that if a new person shows up and starts asking detailed questions most clients get confused and/or angry. This system works for us.

Management decided we are going to send the customer a certified letter asking due diligence questions but the part we are stuck on is who should this letter come from?

I can tell you who should draft it, and that would be your legal counsel. Other than that I agree that it needs to come from the person that is directly responsible for the account relationship.

Thank you both for your responses, truly helpful!