Suspicious Activity Account Closing Procedures

I don't recommend that you make these procedures overly complicated. Ideally, if an account is involved in suspicious activity, there should be an approved process to determine whether continued operation of the account is likely to present an increased risk to the bank or increased costs of monitoring such that the account will cost more to keep than to lose. That decision should be reviewed at an appropriate management level and steps should be taken for an orderly closing of the account. I do not recommend that decisions on closing such accounts be handled at the board of directors level. However, the board should be aware of, and perhaps approve, the bank's policy on account closings of this type.

First published on BankersOnline.com 6/11/07