It's not really 'exempt', it just tends to work differently and in this case other controls are expected to be 'working'. To your first point, it can't be moved

It's not really 'exempt', it just tends to work differently and in this case other controls are expected to be 'working'. To your first point, it can't be moved out of the country/etc. However, Real Estate as a funnel for AML is definitely a thing and normally you'll get trained on it. I think another factor in this case however is the other 'related' controls; if a bank is writing cashiers checks, assuming it's a US Bank of course, for any amount over a few grand they should have done their AML work, thus providing identification/etc when 'qualifying' for the option likely serves as the paperwork required on their end.