Somewhere between asleep and awake, it occurred to me that bank employees (low level employees at that) could market "closed" bank accounts to evil doers for a pretty penny.
In this instance, given the dollar amounts involved, resurrecting the account of an individual was a foolish choice. They should have chosen a non interest bearing account in the name of a small business, supplying only a new mailing address in the form of a P.O. box and trying to keep the activity within the boundaries described by previous histories.
No CIP. No due diligence. Certainly no enhanced due diligence would take place when the account was re-opened. The account could be used, then eventually "closed" for a second time. Perhaps it could even be reincarnated later for a different enterprise...
On the other hand, all a bank would have to do to prevent this is to prohibit in policy and process the "re-opening" of closed accounts or, as it has been described here, the recycling of account numbers.
Naaah, our frontline people would complain about the extra work...