Account Closure Process

Purpose

This procedure defines the end-to-end process for closing client accounts, whether initiated by the client or by the Bank. It ensures that all closures are handled in compliance with regulatory requirements, contractual obligations, and the Bank's internal policies.

Scope

This procedure applies to the closure of all account types held by individual and corporate clients, including current accounts, savings accounts, fixed deposit accounts, and specialised accounts. It encompasses voluntary closures (client-requested) and involuntary closures (Bank-initiated).

Grounds for Account Closure

Client-Initiated Closure

Client no longer requires the account.
Client is relocating to a jurisdiction where the Bank does not operate.
Client is consolidating accounts.
Closure of a deceased client's account by the estate executor.

Bank-Initiated Closure

Regulatory or compliance concerns (e.g., failure to provide updated KYC documentation).
Suspected or confirmed involvement in financial crime.
Account classified as dormant for an extended period (see Dormant Account Handling Policy).
Breach of the Bank's terms and conditions.
Directive from a regulatory authority or court order.

Procedure

Step 1: Closure Request

For client-initiated closures, the client submits a written closure request via the branch, secure online banking portal, or authenticated correspondence. The request must be signed by all account holders (for joint accounts).
For Bank-initiated closures, the initiating department (Compliance, Operations, or Legal) prepares a closure recommendation with supporting rationale, which must be approved by the Head of Account Management.

Step 2: Pre-Closure Checks

The Account Management Officer verifies that there are no outstanding obligations on the account, including pending transactions, unsettled cheques, loan repayments, standing orders, or direct debits.
All linked products (overdraft facilities, credit cards, trade finance instruments) must be settled or transferred before the account can be closed.
The officer checks for any regulatory holds, court orders, or law enforcement freezes on the account. If any are in place, the closure is suspended pending resolution.
For accounts subject to tax reporting (e.g., FATCA, CRS), the officer confirms that all required reports have been filed.

Step 3: Balance Settlement

The remaining account balance (net of any applicable closure fees) is disbursed to the client via one of the following methods: transfer to another account within the Bank, transfer to an external account, or banker's cheque.
For balances below USD 100, the client may request cash disbursement at the branch.
Accrued interest (if applicable) is calculated and credited to the account before final disbursement.
The closure fee schedule is as follows:

Account Type	Closure Fee
Current Account (open less than 6 months)	USD 25
Current Account (open 6 months or more)	No fee
Savings Account	No fee
Fixed Deposit (early termination)	Subject to early withdrawal penalty
Corporate Account	USD 50

Step 4: System Deactivation

The Account Management Officer changes the account status to "Closed" in the Core Banking System (CBS).
All associated access credentials (online banking, mobile banking, debit cards) are deactivated immediately.
Standing orders and direct debit mandates are cancelled.
The client's Customer Information File (CIF) is updated to reflect the closure. If the client holds no other accounts with the Bank, the CIF is marked as inactive.

Step 5: Confirmation and Documentation

The client receives a written confirmation of account closure, including the final statement, disbursement details, and closure reference number.
Confirmation is issued within five (5) business days of closure completion.
All closure documentation is scanned and archived in the Bank's document management system.

Record Retention

Closed account records, including all KYC documentation, transaction history, and closure documentation, must be retained for a minimum of ten (10) years from the date of closure, in accordance with the Bank's Data Retention Policy and applicable regulatory requirements.