[hattmall]

How exactly would this fall into the purview of AML? As far as sanctions go the burden of proof would be on the government to prove the money went to a sanctioned entity and Instructure isn't a bank subject to KYC requirements.

[rsstack]

All my corporate AML training says that not performing some KYC for large payments, directly or through a bank, is a crime in its own even if the recipient isn't sanctioned.

From Claude, maybe it's a little nuanced compared to conservative corporate policies, but doesn't feel very legal: "You can be charged with money laundering (18 USC 1956/1957 in the US, equivalents elsewhere) if you knowingly — or with willful blindness — process proceeds of crime. "I didn't ask" is not a defense if the circumstances were suspicious; deliberately avoiding KYC to preserve deniability is exactly what willful blindness doctrine targets. The recipient doesn't need to be formally sanctioned; the funds just need to be tainted."