Question 102

Perform a transaction review and respond fully to the subpoena

The financial intelligence unit should conduct a thorough transaction review and respond comprehensively to the subpoena issued regarding the client. This process is vital for ensuring compliance with legal obligations and providing the necessary information requested by the authorities.

A) Perform a transaction review and respond fully to the subpoena

This option is correct because it emphasizes the importance of reviewing transactions related to the client and providing a complete response to the subpoena. A transaction review is crucial to ascertain any suspicious activities that may be relevant to the investigation, thereby fulfilling the bank's legal responsibilities.

B) Adjust the client's risk score and close the case

This option is incorrect as it suggests taking action without proper investigation. Adjusting the client’s risk score without reviewing the subpoena could lead to non-compliance with legal requirements, and prematurely closing the case would disregard the need to respond to the subpoena adequately.

C) Close the client's account by informing the client of the subpoena

This option is also incorrect because it lacks the necessary procedural steps. Simply closing the client's account and informing them of the subpoena does not fulfill the bank's obligation to review transactions or respond to the subpoena appropriately.

D) File a suspicious activity report, including the receipt of the subpoena in the SAR narrative

While filing a suspicious activity report (SAR) may be necessary if suspicious transactions are identified, this option is incorrect as a primary response to the subpoena. The immediate obligation is to respond to the subpoena with a transaction review rather than solely focusing on filing an SAR.

Conclusion

The correct answer is definitively the most appropriate action, as it ensures that the bank complies with the legal request while thoroughly investigating the client's transactions. Other options either misinterpret the legal obligations or suggest actions that would not adequately address the situation presented by the subpoena. Thus, performing a transaction review and responding fully is essential for maintaining regulatory compliance and responsible banking practices.