What the bank is doing and why it will not say
Banks, money transmitters, broker-dealers, and other financial businesses are required by federal law to run anti money laundering programs: they verify customers, monitor transactions, and report activity they consider suspicious to the Treasury's Financial Crimes Enforcement Network. A suspicious activity report is confidential, and the bank is generally prohibited from telling you whether one was filed. That is why closure letters are vague and why branch staff often cannot explain a decision made elsewhere. Large cash deposits, frequent transfers abroad, money moving in and out quickly, or activity that does not fit what you told the bank about your work can draw review. None of this means you are accused of a crime, but it can signal that someone is asking questions.
Responding to a source-of-funds request
When a bank asks you to explain a deposit or transaction, your answer and its supporting documents become part of your file. Answer accurately and stay with what you can document: sale contracts, payroll records, tax returns, inheritance papers, loan agreements, or business invoices. Do not guess, and do not offer explanations you cannot support, because an inconsistent answer can do more harm than a careful one that takes a little longer. If you run a cash-heavy business or receive money from family overseas, keep a clear paper trail going forward. Do not split deposits to stay under a reporting threshold; that can be a separate crime even when the money is clean.
When it is more than an account problem
Many closures end with a check for the remaining balance and the need to bank elsewhere. Sometimes, though, a freeze is followed by a seizure warrant, a grand jury subpoena, or a forfeiture notice, and the matter becomes a legal case with deadlines. When you come to us, we look first at what the bank and any agency have actually sent, whether funds are being held or have been seized, and what records exist to show a lawful source. We also consider whether other banks are likely to react the same way and how a business can set up banking going forward. If there is an investigation, we discuss whether and how to engage with it.
