WASHINGTON — Do not be too hasty in closing certain accounts despite suspicious or potentially criminal activity, the Financial Crimes Enforcement Network asked of financial institutions in recent guidance.

While FinCEN acknowledged the decision to maintain any account rests with the institution, the guidance (FIN-2007-G002) stated, "Although there is no requirement that a financial institution maintain a particular account relationship, financial institutions should be mindful that complying with such a request may further law enforcement efforts to combat money laundering, terrorist financing, and other crimes."

NAFCU Director of Compliance Anthony Demangone explained, "The thing that's interesting for credit unions, it's much harder for a credit union to close an account than a bank." Credit unions have to hold a hearing to allow the member to defend him/herself; notification of suspicious activity reports is prohibited. He noted that CURIA has a provision to try to fix that archaic requirement for credit unions to expel members.