---
title: "Decide whether Rule 1.16 requires the firm to decline or withdraw"
url: "https://ailawframework.com/obligations/aml-ctf-the-practice-as-a-reporting-entity/decide-and-record-enhanced-due-diligence-on-a-higher-risk-client/united-states"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A52OB-X20260927-4-US"
practice_area: "AML/CTF — the practice as a reporting entity"
tier: "red"
lawyer_review: "required"
jurisdictions: ["US"]
last_reviewed: "2026-10-22"
---

# Decide whether Rule 1.16 requires the firm to decline or withdraw

> List the facts in the file that bear on whether the client seeks to use the firm's services to commit or further a crime or fraud. Make no recommendation to accept, decline or withdraw.

Canonical page: https://ailawframework.com/obligations/aml-ctf-the-practice-as-a-reporting-entity/decide-and-record-enhanced-due-diligence-on-a-higher-risk-client/united-states  
Last reviewed: 2026-10-22

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [AML/CTF — the practice as a reporting entity](https://ailawframework.com/obligations/aml-ctf-the-practice-as-a-reporting-entity.md) |
| Human involvement | Red: Lawyer writes; AI may check, clarify or collect data |
| How AI is used | List the facts in the file that bear on whether the client seeks to use the firm's services to commit or further a crime or fraud. Make no recommendation to accept, decline or withdraw. |
| What the lawyer must review | Model Rule 1.16(a) requires the inquiry, and Rule 1.16(a)(4) requires the lawyer not to represent the client, or to withdraw, if the client seeks to use or persists in using the lawyer's services to commit or further a crime or fraud, despite the discussion Rule 1.16(a)(4) points to under Rules 1.2(d) and 1.4(a)(5). The lawyer makes that decision. Formal Opinion 512: a tool does not replace the lawyer's judgment. Open the admitting state's rule before acting. |
| Written for | United States |
| Applies to | [Decide and record enhanced due diligence on a higher-risk client](https://ailawframework.com/obligations/aml-ctf-the-practice-as-a-reporting-entity/decide-and-record-enhanced-due-diligence-on-a-higher-risk-client.md) |

## Checking plan

- What the AI does: List the facts in the file that bear on whether the client seeks to use the firm's services to commit or further a crime or fraud. Make no recommendation to accept, decline or withdraw.
- Basis: Checked against the linked sources on 22 October 2026. Confirm the current instrument before reliance.

## Notes

- The tool must not decide whether a client or transaction is declined or reported.
- Withdrawal when a tribunal's permission is required is Rule 1.16(c). Open that paragraph and the state's version.

## Sources

- [ABA Model Rule 1.16, Declining or Terminating Representation](https://www.americanbar.org/groups/professional_responsibility/publications/model_rules_of_professional_conduct/rule_1_16_declining_or_terminating_representation/) (checked 2026-10-22)
- [ABA Formal Opinion 512, Generative Artificial Intelligence Tools (29 July 2024)](https://www.americanbar.org/content/dam/aba/administrative/professional_responsibility/ethics-opinions/aba-formal-opinion-512.pdf) (checked 2026-10-22)

## Forms and precedents for this task

| Form or precedent | Kind | AI level | Summary |
| --- | --- | --- | --- |
| [Enhanced customer due diligence decision record](https://ailawframework.com/precedents/aml-ctf-the-practice-as-a-reporting-entity/enhanced-cdd-decision-record.md) | Form | Red | Record of why enhanced customer due diligence applies to a client under s 32, the measures the compliance officer requires, and whether the practice will start or continue the designated service. |

Signed-in accounts can read the full text of each one.

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*