[hakfoo]

I wonder if it's a scale problem at its heart.

A single-branch local bank could legitimately know their customers on a personal basis and their dealings. Joe-bob comes in with $12k in cash? But we already knew through social circles he just sold his truck, so that's not really suspicious. The guy who has never interacted with anyone outside the county and is suddenly requesting wire transfers to Outer Slobavia? Likely money mule.

I doubt that HSBC can maintain that level of awareness, so we build clunky rules to simulate it.

[valuearb]

Correction: the transfer to outer Slobavia is much more likely for poor family. But the bank will refuse it to minimize their exposure.