CAMS · Question #933
When making an independent determination on whether to close an account based on an internal Investigation, a financial institution (F1) should consider. (Select Five.)
The correct answer is A. reputational risk. D. the Fl's policies and procedures. When independently deciding to close an account, an FI must weigh reputational risk and its own internal policies rather than the customer's personal relationships or other tangential factors.
Question
When making an independent determination on whether to close an account based on an internal Investigation, a financial institution (F1) should consider. (Select Five.)
Options
- Areputational risk.
- Bthe customers personal relationships.
- Cthe frequency of account activity
- Dthe Fl's policies and procedures.
- Ethe seriousness of the underlying conduct.
- Fcorrespondence with law enforcement
- Gthe legal basis for closing the account.
How the community answered
(49 responses)- A76% (37)
- B4% (2)
- C12% (6)
- E6% (3)
- F2% (1)
Why each option
When independently deciding to close an account, an FI must weigh reputational risk and its own internal policies rather than the customer's personal relationships or other tangential factors.
Reputational risk is a core consideration because maintaining a relationship with a high-risk customer can damage the FI's standing with regulators, correspondent banks, and the public. The FI must assess whether continued association creates unacceptable exposure beyond the direct financial crime risk. This factor anchors the closure decision within a broader enterprise risk management framework.
A customer's personal relationships are not a permissible or objective factor in a risk-based closure determination and could introduce unlawful bias or discrimination.
Frequency of account activity may be reviewed during an investigation but is not a standalone determinative factor in the independent closure decision framework.
The FI's policies and procedures provide the internal governance framework that must guide every account closure decision, ensuring consistency, legal defensibility, and regulatory compliance. Acting outside established policies without documented justification exposes the FI to supervisory criticism and potential liability.
The seriousness of underlying conduct informs the investigation phase but is not identified as a primary independent factor specifically governing the closure determination itself.
Correspondence with law enforcement provides investigative context but is not a primary independent factor the FI weighs when making its own account closure determination.
The legal basis for closure is a procedural prerequisite rather than one of the substantive risk-based factors considered during the independent determination.
Concept tested: Risk-based account closure determination factors
Source: https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-risk-based-approach-banking-sector.html
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