Skip to content
BOL Conferences
Thread Options
#2281938 - 03/07/23 08:58 PM Fictitious Account Per LE Request
TXBSA Offline
New Poster
Joined: Sep 2021
Posts: 2
Good Afternoon,

We have been requested by a law enforcement agency to open a fictitious account. It would only be open for a finite time to assist with a criminal case. Provided we have the documentation on file of the request to open the fictitious account from LE, would anyone anticipate an exam issue down the road?

As we all know, LE will request financial institutions to keep accounts open that are facilitating criminal activity that would have otherwise been closed by the institution. In my estimation, this equates to that. We just need proper documentation of the request on file.

Thank you.

Return to Top
BSA/AML/CIP/OFAC Forum
#2281943 - 03/07/23 09:33 PM Re: Fictitious Account Per LE Request TXBSA
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,370
Galveston, TX
I would have no problem with it.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2281947 - 03/07/23 09:41 PM Re: Fictitious Account Per LE Request TXBSA
TXBSA Offline
New Poster
Joined: Sep 2021
Posts: 2
My thoughts, as well. Thank you for the reply.

Return to Top
#2282044 - 03/09/23 04:04 PM Re: Fictitious Account Per LE Request TXBSA
HappyGilmore Offline
10K Club
Joined: Jun 2004
Posts: 19,855
Pulling people out of the ditc...
we have an account that has been opened for a lengthy period of time that is used by an agent of the US Government that is used for similar purposes. We have never had an issue with any exam as a result of holding this account.
_________________________
Providing alternative truths since the invention of time

Return to Top

Moderator:  Andy_Z