Relationship Exit (Customer Offboarding)

Reasons include a customer who will not supply information, an inability to identify the beneficial owner, repeated suspicious activity, links to sanctions, or risk beyond the firm's appetite. Exits are normally approved by senior compliance staff and recorded with reasons. Practical steps include giving notice where the law allows, returning funds in a controlled way, blocking new activity, and preserving records. Where a suspicious activity report has been filed, staff must take care not to tip off the customer, and may need to consult the financial intelligence unit before closing. Some countries limit closures without notice or require fair treatment. Exit differs from de-risking, which is the broad withdrawal from whole groups of customers instead of judging individual risk. Done carelessly, an exit can tip off a suspect or strand an innocent customer with no account.

A trading customer has been the subject of two suspicious activity reports and refuses to explain a series of third-party deposits. Compliance recommends exit. Before sending notice, the money laundering reporting officer checks with the financial intelligence unit, which asks the bank to wait two weeks. The account is then closed and the balance returned to the customer's own name.