So I found this interesting article on the internet about the practices of the UK bank Standard Chartered over 15 years ago:
https://www.buzzfeednews.com/article/richholmes/standard-chartered-bank-money-iran-fbi"Two employees blew the whistle on Standard Chartered's accounts. The FBI wasn't interested. But the bank's own reports raised similar concerns."
The Government And The Whistleblowers
Confidential records from the FinCEN Files show that the bank was reporting its own suspicious transactions about customers with links to Iran until at least 2017.
On a summer morning in 2012, Anshuman Chandra read a news article about a Saudi Arabian financial institution suspected of facilitating the funding of al-Qaeda attacks, including 9/11. The bank was called Al Rajhi, and a US Senate committee cited allegations it had handled payments to suicide bombers in Somalia, Sri Lanka, India, and the Philippines.
Chandra was deeply troubled, he said, and not just because he knew people who had died in terrorist attacks. He was disturbed because Chandra worked for Standard Chartered bank, and he realized that his employer was doing business with Al Rajhi.
So Chandra warned a supervisor about what he had learned, he said, but he never heard back.
From Standard Chartered’s Dubai office, where Chandra was a client services manager, he dug deep into bank records. He later learned, examining a yearly profit report, that in 2009 alone, Standard Chartered earned $2 million from its relationship with Al Rajhi. (Al Rajhi did not respond to a request for comment.)
But that wasn’t all. Poring over Standard Chartered’s accounts, he found a number of customers in Iran, a country under US sanctions, and Chandra feared that they too had been indirectly supporting terrorist activities.
“I actually got goosebumps,” Chandra said.
This time, he decided to bypass his bosses. He turned to the US government.
By the fall of 2013, Chandra and another whistleblower, Julian Knight, had handed US authorities thousands of internal bank records that they claimed show Standard Chartered was giving safe harbor to a number of customers moving money to Iran.
The documents came at a significant time. A year earlier, the bank had acknowledged its role in concealing tens of thousands of transactions with businesses in Iran. Under threat of criminal prosecution, the bank had agreed to clean up its act.
Ultimately, the government walked away from the whistleblowers. But the two men had flagged real problems. The bank itself, confidential records show, later reported to the US Treasury that it had suspicions about at least 31 companies contained in the data the whistleblowers had handed over.
So as you can see, these banks can get away with not only money laundering but even terrorism financing. But then let's take the case of Samourai Wallet, which the prosecutors call a mixer (it wasn't). The Whirlpool coordinator was targeted for "allegedly" being used for money laundering despite a complete failure to identify
who was using the service. However, in the case where the government has all the information about the banks' customers, transactions, accounts, and who is violating the law, they did not do anything. Actually, they didn't care.
What I'm seeing here in the regulations is less of a genuine concern to prevent AML and feels more like it's just a partisan jab in order to hurt non-democrat's standings in elections.
See also:
https://stacker.news/items/532922