I think that is mostly, because no good bank will rely on an automated process for this. Not one bank I have been to had 'derisking'/'divestiture'/'whatever the

I think that is mostly, because no good bank will rely on an automated process for this. Not one bank I have been to had 'derisking'/'divestiture'/'whatever they call it there, because, surprise, this idiocy is not standardized; government just gave companies general idea of what it wants without actual mechanisms' that was ultimately dependent on an automated process. The decision was always human with bankers ( especially commercial ones ) arguing for 'their' customers. Now, I do not know how bad fintech scene is, but I do know that they generally suck when it comes to actual BSA compliance. Then again, I do not really consider fintech banks. Neither does treasury for that matter[1]. Still, this is not THE problem even if you raised a valid and relevant concern here. The issue is and always has been BSA legislation that put this requirement on banks without specifics. More than that, the core issue is that the stupid population that was so scared post-9/11 that it let this thing pass through with minimal whimper. Clearly, it got bad enough that it got some important people and Treasury had to issue a guidance[2]. No one cared for 2 decades. I am sorry for the tone. I am glad this is getting a wider audience, but I do have a bee in my bonnet that it took this long. [1]https://home.treasury.gov/news/press-releases/jy1105 https://home.treasury.gov/news/press-releases/jy1105 [2]https://home.treasury.gov/news/press-releases/jy1438 https://home.treasury.gov/news/press-releases/jy1438