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#1560596 - 06/03/11 08:02 PM BSA policy
ackcompliance Offline
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Joined: Nov 2009
Posts: 139
Is our BSA Policy required to have procedures for closing accounts as a result of continuing suspicious activity?

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BSA/AML/CIP/OFAC Forum
#1560613 - 06/03/11 08:20 PM Re: BSA policy ackcompliance
Doug Hendrickson Offline
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Doug Hendrickson
Joined: Oct 2009
Posts: 3,927
The examination manual states that "The bank should develop policies, procedures and processes indicating when to escalate issues...should include...criteria for when analysis of the overall customer relationship is necessary...and...criteria for whether and, if so, when to close the account.
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#1560615 - 06/03/11 08:22 PM Re: BSA policy ackcompliance
Ted Dreyer Offline
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Ted Dreyer
Joined: Apr 2001
Posts: 2,245
You should have procedures that include "criteria for whether and, if so, when to close the account" according to page 76 of the BSA/AML Exam Manual.

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#1560649 - 06/03/11 09:08 PM Re: BSA policy Ted Dreyer
ackcompliance Offline
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Posts: 139
Ok, thank you! & thanks for the manual reference. smile

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#1570447 - 06/27/11 06:09 PM Re: BSA policy ackcompliance
ackcompliance Offline
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Joined: Nov 2009
Posts: 139
Asked above:
"Is our BSA Policy required to have procedures for closing accounts as a result of continuing suspicious activity?"

Ok,so the manual says that we "should" develop policies and procedures that outline the criteria for whether and, if so, when to close the account; does that mean that we have to include this in our policy? I am having a hard time trying to figure out what criteria would constitute closing an account. Does anyone have an example of this in their policy?

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#1570457 - 06/27/11 06:05 PM Re: BSA policy ackcompliance
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
I have two criteria:

Does the customer present a risk of loss to the bank?

If, considering all the additional monitoring and paperwork required, is the customer still profitable?

If the answer is not no and yes, I would close on the first occurrence or any subsequent occurrence where those answers changed.
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