Regulatory exit compliance check

The agent does not confirm the closure. It returns a pass/fail pack that cites the dormancy, CASS, and unclaimed-asset rules that apply to this product and this jurisdiction, and it names the source systems behind each finding. A fail leaves the confirm control locked. An empty CASS field stays empty. A human still confirms a pass.

Treat model confidence as irrelevant. Confidence is not a cite. If the ledger, the client-money register, or the unclaimed-asset workflow is silent, the pack records silence. Inventing a CASS balance, including a rounded zero that was never read from a CASS system, is a fail.

The pack is a quality gate, not a narrative. Each obligation that is in scope gets a rule reference, a system of record, a result (met, not met, or not in scope), and the evidence used. Obligations that are out of scope get an explicit out-of-scope line with the product and jurisdiction reason, not a blank that a reviewer might misread as cleared.

Do not let a clean story in the CRM override a break on the books. The confirm button stays off until every in-scope line is met and every out-of-scope line is justified.

Run the obligation map first. Do not load a generic UK CASS-plus-dormancy checklist onto every closure.

Start with product and book. A sterling personal current account on the bank's own deposit book is not a CASS client-money arrangement. CASS (the FCA Client Assets Sourcebook) governs client money and custody assets the firm holds for clients, not the bank's own deposit liability. A wealth or custody wrapper, a designated client-money account, or a safe-custody holding can be in CASS even when it sits next to a deposit in the same customer file. If the product is not in CASS scope, the pack says not in scope and cites the product classification. It does not print a CASS balance.

Then apply jurisdiction. Dormancy and unclaimed-asset paths are local. A UK retail deposit may fall under the UK dormant-assets framework and the firm's own dormancy policy. A US-state deposit book is usually an unclaimed-property path under that state's rules, with different notice, holding-period, and remittance steps. A book booked in another host location can add a second unclaimed-asset statute. The agent checks the rules that apply to this account's booking location and product, not every statute the bank has ever filed.

Closure reason is an input to the path, not a waiver. Closure reason classification tells you whether this is customer-requested, deceased, bank-initiated, or another coded reason. Death or dormancy can change notices and payees. It does not let you skip the unclaimed-asset path when the account already meets the dormancy test.

KYC freshness at exit is a separate gate. If perpetual KYC refresh shows the file is expired, restricted, or mid-review, the exit pack fails until that status is resolved or explicitly waived under policy. Do not treat a clean CASS line as covering identity.

Open financial-crime work also fails the pack. An unresolved AML case disposition at funding, or any still-open SAR, freeze, or investigation flag on the same customer or account, blocks confirm. Closing the account does not close the case.

Every line in the pack names a source system and a rule, or it is not a finding.

Balances and residual credits come from the books, usually via the same evidence the balance and payment reconciliation agent uses: core ledger, payment rails, pending items, and unapplied credits. Core banking platforms such as Temenos, and case or servicing records in CRM platforms such as Salesforce, are sources to read. They are not substitutes for a missing figure. If Temenos, or the equivalent core, has no CASS sub-ledger for this product, you do not derive a CASS number from the deposit balance.

CASS evidence, when the product is in scope, comes from the client-money and custody registers the firm already uses for CASS reporting: client-money account identifiers, custody positions, reconciling items, and the last completed internal CASS recon. If those registers return no row, the field stays empty and the line is fail or not in scope, depending on the product map. Never back-fill a CASS figure from a language model, from a neighbouring account, or from an assumption that retail is usually zero.

Dormancy evidence is last qualifying customer-initiated activity per the book's definition, plus any statutory clock, plus whether the unclaimed-asset or dormant-assets workflow has already been opened. Servicing notes in Salesforce, or the equivalent CRM, can explain contact attempts. They cannot replace the activity date on the ledger.

Unclaimed-asset evidence is the workflow state: notice issued or not, transfer to the scheme or state unclaimed-property office initiated or not, escheat hold, estate payee, or still on book. Closing a dormant account without that path is a fail even if the residual looks small and the customer is unresponsive.

Rule cites should be specific enough to audit: the internal policy paragraph, the CASS rule that applies if in scope, the dormant-assets or unclaimed-property provision for this booking location. "Regulated" is not a cite.

Keep confirm locked unless every in-scope line is met and every out-of-scope line is justified.

Closing a dormant account as if it were a live customer-requested closure is a hard fail when the unclaimed-asset or dormant-assets path has not been started, or completed, as policy requires. The residual must follow that path, not a standard close-and-pay-away action. Paying the residual to a stale mandate, to a new account the model suggested, or to suspense without the statutory route, is also a fail.

Inventing a CASS figure is a hard fail. That includes a fabricated zero, a copy of the deposit ledger labelled as client money, and a rounded estimate. If CASS is not in scope, say so. If CASS is in scope and the register is empty or unreconciled, fail. Empty stays empty.

Passing because the model is confident, while the ledger is not, is a hard fail. Typical breaks: pending credits still on the payment rail, unreconciled items on the reconciliation pack, a CASS recon break, a dormancy clock the core has not actually calculated, or a CRM note that says the customer has gone away with no activity date behind it. The pack follows the systems of record. If they disagree, fail and surface the break.

Other blocking fails include product or jurisdiction not classified, a missing rule cite, an open freeze, incomplete deceased-estate paperwork where policy requires it, and a financial-crime case still open. A KYC status that blocks servicing fails the pack even when balances match.

A pass means the pack is complete and every in-scope obligation is met. It still does not close the account.

A closures analyst receives a UK personal current account marked for bank-initiated closure. Last customer-initiated activity on the core is older than the book's dormancy threshold. The ledger shows a residual credit. There is no client-money or custody position, because this is a deposit on the bank's own book.

The agent maps product and jurisdiction first: UK retail deposit, CASS not in scope, UK dormancy and dormant-assets policy in scope. It cites the product classification rather than writing a CASS balance of zero. It pulls the residual and pending items from core banking (a Temenos-class ledger) and from the reconciliation pack. It reads servicing notes in a Salesforce-class CRM for gone-away flags, but it dates dormancy from the ledger. Closure reason classification returns bank-initiated dormancy, which selects the unclaimed-asset path rather than a customer-requested close.

If the unclaimed-asset workflow has not been opened, the pack fails and confirm stays locked. If the residual still has an unapplied inbound payment, the pack fails until reconciliation clears it. If someone had typed a CASS client-money balance of 0.00 into the pack with no CASS register behind it, that line is stripped and the pack fails.

When the path is open, CASS is correctly out of scope, balances match the ledger, and no crime or KYC block remains, the pack returns pass with cites. The analyst, or the designated approver, still confirms. The agent never flips the account to closed on its own.