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Closing Money Laundry Suspect's Loan Account

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If I suspect money laundering in a commercial loan account, to the point where I am going to submit a SAR, what options do I have for closing that account? Assume that I strongly suspect money laundering, but cannot prove it definitively.

You'll need to refer to the loan agreement with that borrower. It will include a list of the events that trigger a default. It's highly unlikely that you'll have an option to declare the loan in default simply because you have suspicions of money laundering. Get the loan officer spun up on your concerns, but caution him or her not to make inappropriate comments to the borrower. The lender may be able to provide you with information the explains the borrower's actions. The lender might also agree with your suspicions and can keep them in mind at the next opportunity to review the lending relationship.

First published on 8/27/07

First published on 08/27/2007

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