What are other bankers doing in regards to subpoena's and GJ Subpoena's for BSA purposes. The other FI I was at never looked at them for BSA purposes. Any guidance anywhere?

Whenever we receive a subpeona, gj subpeona, summons, and the like, we do a review and determine whether or not a SAR should be filed for any activity which was not previously on our radar.

LuvforBSA: There is some guidance on page 65 of the BSA Exam Manual.

From the Manual:
Mere receipt of any law enforcement inquiry, does not, by itself, require the filing of a SAR by the bank.
Nonetheless, a law enforcement inquiry may be relevant to a bank's overall risk assessment of its customers and accounts.
For example, the receipt of a grand jury subpoena should cause a bank to review account activity for the relevant customer.
It is incumbent upon a bank to assess all of the information it knows about its customer, including the receipt of a law enforcement inquiry, in accordance with its risk-based BSA/AML compliance program.
The bank should determine whether a SAR should be filed based on all customer information available.

What about subpoenas related to civil claims? Or does this apply to just criminal subpoenas?

My institution does not receive an abundance of subpoenas, so I have time to review them all, both criminal and civil, for suspicious activity.

We have a separate department that handles the research of the subpoenas and then forwards a copy to the BSA Department for final review. If we determine that the customer has had suspicious activity then a SAR is filed. We never assume just because a subpoena is received that the account is suspicious.

My question relates to accounts that have been closed for a number of years- our Legal Department sends to the BSA Unit copies of Grand Jury Subpoenas so that the pertinent accounts can be reviewed for possible suspicious activity. However, there are a lot of subpoenas for accounts closed years ago- there is no longer any relationship in any way shape or form- so do we have to get out the old records and review? If it is felt that this is not necessary what should the number of years be that we do not conduct a review- e.g. accounts closed two years or more will not be reviewed.