Scenario: New checking account open a year. Customer is a criminal attorney. Account styled Bubba Smith dba Law Offices of Bubba Smith. Customer deposits cash several times a week, no CTRs, total cash deposits approaching $400,000. Very few client checks deposited. Funds are used to wire overseas to purchase a home. Account is never overdrawn, no account mismanagement. SAR considerations aside, what legitimate, supportable reasons are there to close the account? We don't want an attorney filing a lawsuit against us. We would obviously have our own attorney in on the process and would follow his recommendations, but I'd like to get feedback from other FIs about what they've done in situations where they wanted to de-risk a customer because of BSA concerns.

Review your account agreement which should have a clause that states that you reserve the right to close an account at any time for any reason. The way to avoid a lawsuit is to exercise your right to terminate the deposit contract and send your customer notice to that effect. You don't give a reason in this letter other than to refer to the terms of the contract. By not providing a reason, there is no libel, slander, etc. that anyone can claim. Less in more in these circumstances.

Below is the short and simple language we use.

This letter is to inform you that ABC Bank is exercising its rights as outlined in the terms and conditions provided to you when establishing your account and no longer wishes to maintain a banking relationship. Your accounts will be closed effective May 31, 2019 and if there are funds remaining in the account at that time, a check will be sent to you for the balance. In the interim, please make sure that you redirect any direct deposits or payments as those often take a couple of weeks to be changed. Thank you.

both of the above are to the point, nothing else to add