Anyone alive in this discussion (besides me) who remembers the big KYC proposal that went down in flames after the FDIC got thousands of angry comments? Pre-9/11.
Yep - and the regulators then shifted the KYC components into SAR filing expectations and and non-SAR filing explanations - i.e. how can you explain that these activities are suspicious or are NOT suspicious if you don't know your customer?
Then 9/11 happened and all H-E-double-hockey-sticks broke loose.
And you know, I still hear people talk about how their uncle or accountant has told them to always be sure to deposit less than $10,000 in cash because otherwise the bank files a report with the IRS that will trigger an audit. For reals.