When should a financial institution (FI) exit a relationship? (Choose two.)

Question

Options

• AThe reputational risk to the FI posed by closing the account
• BThe request from law enforcement to close the account
• CThe FI's requirements for opening an account
• DThe suspicious conduct of the account holder
• EThe FI's stated policies and procedures for closing an account

• A
  14% (7)
• B
  2% (1)
• C
  6% (3)
• D
  78% (38)

Explanation

A financial institution (FI) should exit a relationship when the suspicious conduct of the account holder or the FI's stated policies and procedures for closing an account warrant such action. A FI has the right and responsibility to terminate a customer relationship that poses an unacceptable level of risk to the FI or violates its AML/CFT program. A FI should have clear and consistent criteria for exiting a relationship, such as the number and severity of SARs filed, the nature and extent of due diligence conducted, the availability and effectiveness of mitigating controls, and the alignment of the customer profile with the FI's risk appetite. A FI should also document the rationale and process for exiting a relationship, communicate the decision to the customer and relevant stakeholders, and monitor the account until closure. The reputational risk to the FI posed by closing the account or the request from law enforcement to close the account are not valid reasons for exiting a relationship by themselves. A FI should consider the potential reputational impact of closing an account, but it should not outweigh the legal and regulatory obligations of the FI to prevent and detect money laundering and terrorist financing. A FI should also cooperate with law enforcement requests, but it should not automatically close an account based on such requests, as they may interfere with ongoing investigations or intelligence gathering. A FI should exercise its own judgment and discretion in deciding whether to exit a relationship, based on its own policies and procedures and the facts and circumstances of each case.

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