Upon filing a suspicious transaction report, which of th€ following elements should be the highest anti-money laundering priority in making the decision to keep the account open?

The decision to maintain or terminate a customer relationship after filing a suspicious transaction report (STR) must be driven by a comprehensive risk assessment. The highest anti-money laundering (AML) priority is to evaluate the ongoing risk the customer poses to the institution, including legal, regulatory, and reputational risks. This evaluation, guided by established procedures, determines whether the risk is manageable through enhanced monitoring or if it is unacceptably high, necessitating account closure. This aligns with the fundamental risk-based approach mandated by global AML standards.

A. Financial impact on the institution if the account is closed. This is a business consideration, not an AML priority. Financial concerns should not override the institution's legal and ethical obligations to manage and mitigate money laundering risks.
C. Additional Administrative costs of monitoring the account. While a valid operational factor, cost is secondary to the primary AML obligation of managing risk. The decision must be based on risk level, not the expense of compliance.
D. Total number of accounts the institution closed in the last month. This is an irrelevant operational metric. Each customer relationship must be assessed on its own merits and specific risk profile, not based on aggregate statistics.

1. ACAMS CAMS6 Study Guide (6th Edition). Chapter 4, Section 4.5, "Closing an Account." The guide explains that the decision to close an account is a significant one that should be based on a risk evaluation. It states, "The decision to close an account should be made by senior management or a committee... based on a variety of factors, including a reputational risk analysis." This underscores that risk assessment is the central element.

2. Financial Action Task Force (FATF). Guidance for a Risk-Based Approach for the Banking Sector. October 2014. Page 23, Paragraph 63. This guidance states that when a financial institution assesses a customer as posing a higher risk, it must take enhanced due diligence measures to manage and mitigate that risk. If those risks cannot be mitigated, the institution "should be required to terminate the business relationship." This directly links the decision to the outcome of a risk assessment.

3. The Wolfsberg Group. Frequently Asked Questions (FAQs) on Risk Assessments for Money Laundering, Sanctions and Bribery & Corruption. 2015. Page 10. The document emphasizes that a risk assessment is the "foundation" of an institution's AML program. All subsequent actions, including ongoing monitoring and relationship management decisions, are predicated on the understanding of risk derived from this assessment.