Our CIP/CDD process is applied consistently across all bank products. Most of the time the basic CDD questions, which are difficult to get answered on the retail side, are part of safe and sound lending practices. For example, most loan officers know, in detail, the purpose of the loan, the origin of funds (As it relates to repayment) and the actual beneficial owners of any complex legal structures.
It's been my experience that risk rating loan accounts is far easier than retail accounts, as a good loan officer really does know his customer.
Unless you're dealing in trade finance or letters of credit, most loans are going to be low to medium risk in terms of AML risk.
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu