| It basically is how you say it should be, with the pre-sorting distributed to the leaves of the tree (banks and funds). When a client approaches you, broadly, you have to sort them into low risk, medium risk and high risk. Low risk you waive through. Medium risk you do some digging on but if you’re then happy, you continue. High risk, you alert the authorities. Then they take care of this. You put the client on hold. The authorities may later give you a formal go-ahead. At least this is how AML works in Europe, I’m less familiar with US. So if the institution is concerned enough to refuse services, they absolutely must alert financial supervisors too, and it’s up to them how to proceed. They give you the go-ahead or the red light. Strictly speaking you could still refuse a client then, eg if you think they could be on a sanction list soon enough, but that’s business reasons, not supervisory. |