I think the general theory is that the equipment lease product is a low risk for money laundering. FinCen in granting an exemption to the new Beneficial Ownership rules to equipment finance companies states that the product is a low risk for being used as a vehicle for money laundering. The reason I'm seeking comment is that we're having discussions about setting the thresholds for cutoffs between Low, Moderate and High Risk. In the absence of other banking products would there necessarily be a larger percentage of high risk customers. There's no set standard of how many customers in each category you should have (i.e. 10% should be high, 50% moderate etc. etc.) based on the overall risk profile of your organization. I found it a bit odd that the org I talked to would make it impossible to have a high risk customer (if only lease product) but maybe its me that's odd so i wanted to get comments from others.