What you need to do to be fair is to quantify what the fee is for, not assess it based on your customer's membership in a "class" of customers. In my opinion, you start with the idea that the fee is for monitoring then you add blocks based on the customer's activities:
* international transactions including IAT's,
* selling and reloading open system prepaid access devices,
* ACH origination,
* cashing checks,
* selling checks,
* currency exchanges,
* wire transfers.
This whole "de-risking" mess creates an expectation that banks will do a risk assessment before refusing to open an account. The secondary effect of that risk assessment should be to assemble the blocks of an appropriate fee schedule for customers that you do intend to bank. If anything provides an incentive for ongoing due diligence it would be the idea that you want to make certain that the customer's activities are as predicted because you want to make certain you have attached the right fee schedule.
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.