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People are massively dishonest about this, though. Like there are occasional Ask HN posts where someone is outraged that their bank/payment account was closed for “no reason”, but eventually it comes out that they’re in North Korea selling cannabis to Iran or something.

But it does seem like the world lacks a manual on How Not To Get In Trouble With Your Bank. “Structuring” in particular is something someone might innocently do just because they like round numbers.



Funny enough. Whenever possible, I round all my tips to cause the total to generate a particular two digit cents amount - so that I can easily detect fraud when I scan my statements. It’s my low tech error code check.


I get a notification on my phone when any money is deposited or withdrawn from my account. If its not something I've just done or an unexpected amount, then its probably fraud and I can tell my bank.


In the US, restaurants immediately charge the price of the meal (without tip). Then the next day the restaurant updates the amount of the original charge to add on the amount you added as a tip.

That means shady restaurant could change your tip the next day if they wanted to pull a fast one on you.

In other words, it’s not possible to get an immediate notification of the total amount charged including tip until 1-2 days after the meal.

(Don’t ask me why the system works this way, makes no sense to me)


It works that way because in the 1980s that was the only way to make it work at all, and it still works that way because being able to do the equivalent of an HTTP OPTIONS preflight for money is actually quite useful.


A restaurant could ask for the tip before charging the card.


That's how it works in Europe.

In fact, the card terminals themselved ask how much you want to tip when you pay and then the card payment is taken on the total. I don't think it would be possible to proceed another way with all the safety procedures in place nowadays.

Otherwise, people used to leave cash on the table when they left even if they had paid by card (meal only) and they wanted to tip.


In the US, it'd be considered déclassé in most sit-down restaurants for the customer to run their own card. You see it at fast food and "fast casual" places, but not really anywhere fancier; to a good first approximation you can quickly understand in which market segment a restaurant would like you to perceive it by how easy or difficult it is to see any point-of-sale equipment from anywhere in the dining area.

I have the sense that tipping is much more customary in the US than in Europe, which may also make a difference. Certainly there is a significant semiosis around the concept here, which would also have to change in response to a change in the shape of the practice; I don't know exactly how much that contributes to things staying as they are, but I doubt it's of no import.


> In the US, it'd be considered déclassé in most sit-down restaurants for the customer to run their own card.

Interesting; I rarely carry a card and just pay with my phone. I've never been to the US, but it certainly wasn't an issue when I visited Canada. I should probably remember to take my card if I visit a restaurant in the US.


I'm old-fashioned enough to prefer carrying a discrete wallet, not least since my barbershop is cash-only, but also because to forgo it would promote a lost or broken phone from headache to catastrophe.

That said, I assume even restaurants whose POS equipment is well hidden would be generally able to handle folks who prefer the single point of failure.


> In the US, it'd be considered déclassé in most sit-down restaurants for the customer to run their own card.

Oh, I see. The US are so 1980s ;)

In Europe all card payments are chip-and-pin so they have to hand the card machine to you for you to type your pin.


Yeah, there's a lot of tech debt here owing to us having invented payment cards and all ;)

EMV is pretty common here these days, but evidently optional for restaurants; I suspect there's a carveout in the relevant association rules.


Okay. Now:

- every restaurant PoS has to be updated to handle this use case;

- you have to wait for your server to make a second visit to your table before you can sign your tab and leave;

- every server has to spend extra time dealing with every table's tab upfront, rather than settling after close when no customers are inconvenienced by the time that takes;

- and all this cost and friction to reduce the incidence of a kind of low-value card-present fraud which is trivial for the customer to have reversed, and quite rare in all respects save the purely anecdotal.

If you're going to worry about any kind of payment card chicanery at a restaurant, the thing worth looking out for is skimming, not this.


I use palindromes. Easy to check and will catch extra dollars added.


Has this ever turned up anything suspicious?


It actually did. At a wings place I noticed a total that wasn’t my usual last two digits. I called up the place and they confirmed they had an employee who had been altering tip amounts and also skimming cards. They advised me to call my credit card company and ask for a new card. It is now a well defined muscle memory for me. Therefore for very little effort I get a desirable side effect of easy detection. My teen son currently rolls his eyes when I fill out the receipt but I suspect he’ll adopt the habit in some form over time.


What about routine credit card transactions that you don’t tip on? Isn’t that the bulk of purchases ?


He's the guy that tips at grocery stores.


Transactions that don't involve latency in knowing the final amount also don't offer the same opportunity for chicanery.


I track almost all of my expenditures. At a restaurant I used to visit fairly regularly I noticed that my costs were often off by approximately ±25 cents. This was inconsistent and not always in one party's favour. Upon reporting and investigation it turned out that (a) I routinely wrote 'math' along with a total instead of a tip and (b) one of the waiters only approximated the math required.

Nothing nefarious and I'm not even sure if I won or lost out of this - but it was interesting to catch.


I had to reread this because it didn't make sense to me the first time because it's so insane.


Not surprising, right? I don't know what you expected implicitly asking them to do the arithmetic for you, but I would've assumed not much care would be taken.


> I routinely wrote 'math'

Why would you do this?


1+ bottle wine?


> I routinely wrote 'math' along with a total instead of a tip

I, too, am dying to know why you do this. I assume that you didn't intend it to be punitive, but that's what it looks like to me.


I've heard that half the time a restarant's POS is configured to ask the waiter to enter the number written on the tip line, but the other half of the time, it's configured for the them to enter what's written on the total line. Meaning, in the first case, writing "math" means more work for the waiter, and in the latter case, you better be careful the amount you wrote on the total line is accurate.


Catch what? Why would you do something so silly


Writing both the tip and total adds redundancy which helps to avoid data entry mistakes.


Is it 69?

It's 69.


My guess is 42.


Anecdata, but I've had both my bank account and Stripe account closed for basically "no reason".

I still don't know why Stripe closed my account (I was selling cheap USB oscilloscopes online, never had a complaint. Couldn't get in contact with them at all when it happened.)

My bank account was closed because I filled in a KYC form incorrectly, and they didn't have a process in place to follow up properly when this had occurred.


    My bank account was closed because I filled in a KYC form incorrectly, and they didn't have a process in place to follow up properly when this had occurred.
I'm tired of HN anecdata about "bank account was closed because of silly reason X". I sincerely doubt we are getting the full story. Step 1: Send a written complaint to the bank and use mail tracking. Then they cannot deny it was not received. Step 2: Report this to your local banking regulator.


You seem very emotionally invested in the idea that banks don't make mistakes. What is that all about?


I’m pretty sure that they absolutely know that banks make mistakes.

But if you’ve never been on the other side providing customer service, you may be astonished at the systemic fraud/illegal attempts happening constantly.

When I did CS at Blizzard for WoW at least half our work was dealing with compromised accounts (essentially by gold sellers), and then a good deal of “I’ve been hacked!” tickets were by the thieves trying to double steal from an account.

To put that in perspective, it was $100,000s or $1,000,000s in CS costs per month (at just Blizzard) to help customers who were victims of a large scale full time industry (not individuals, organisations) which compromises accounts to make a living.

People banned for confirmed cheating with 3rd party programs would make support requests repeatedly in the hope they’d come across an agent who “makes a mistake and accidentally unbans them”, occasionally you would see lots of them trying the same strategy or telling the same story since they saw a forum post of someone who said “this worked for me”.

Legitimate mistakes happen, but they’re like 1% of the time, the rest of the time it’s systemic attempted fraud.

So the person you’re replying to is most likely aware of this reality and says that “complaining on forums” is most often by people who aren’t telling the full story.

Hence them saying, if your story is legit, take it to the right place to get help, otherwise you’re looking like a just another fraudster (who do this systematically) trying to game the system in some way.


So maybe it's a bad business model. If your business model requires you to choose between rampant fraud or randomly firing customers, it's a bad business model.


[flagged]


Making an honest mistake on a complex form isn't "lying" and neither is it an offense that warrants financial punishment. What the heck?


How about seeing like a bank? From bank's point of view it could be either honest mistake or deliberate lie. And if person is lying and have been caught - they always say it was an honest mistake.


All the bank knows is that they tried to get to know someone as required and that person gave them bad info. This is either intentional or unintentional.

Now, they could go in for a high-touch customer care process, but that has drawbacks. It's expensive. Every person intentionally providing incorrect information is going to claim it's unintentional, meaning that this high-touch customer care process is going to have to double as a strong anti-fraud screening. From the bank's perspective, this is failure-prone and needlessly risky.

If we're seeing like a customer, this is a shitty experience that they can't understand, negotiate, or do anything about. They're being punished and don't know why. If we're seeing like a bank, it's a way to control a risk for a known price.


Have you read the relevant KYC laws and regulations that the bank must follow? Otherwise how would you know this to be the case?


Completely agree that banks should provide prescriptive guides.

IME they really don’t like when you work around their eg 50k/day ACH transfer limit by initiating 50k ACH transfers on 4 consecutive days to move an account of 200k. But they don’t tell you what they actually want you to do if you want to move 200k - and for obvious reasons they probably don’t want to make these transfers fully frictionless. They just assume you’ll know to show up at a branch in person or get on a phone to ask about it and treat you like a criminal if you don’t.


Is that even "working around" the restriction? Surely moving 50k on each of 4 days is what you're expected to do in that case. It still means the maximum a fraudster can get away with is 50k if the fraud is discovered in one day.

My last bank had limits like 20k/day and 50k/week, so it seems like yours could have 50k/day and 60k/week if they "really don't like" you using it like this.


One of the reasons banks have these restrictions (besides the obvious thing of making it difficult to take large sums of money out because it hurts their business) is to prevent fraud. They want to prevent the case where some criminal gets physical access to my computer, or my login credentials, and drains my account without my knowledge. So they want you to initiate a manual verification that you really do intend to move such a large sum to prevent that fraud.

If you do what I did, you usually get a temporary hold on your account and some very skeptical bank employee calling you to grill you on what you’re doing.

On one hand I get it. For every story like mine, where this is just a temporary frustrating inconvenience, there’s probably a story where grandma lost her life savings after talking to the nice man from Microsoft on the phone. But also they don’t make it clear at all what you are supposed to do as non-criminal to work around their restrictions, which is just bad for customers.


> So they want you to initiate a manual verification that you really do intend to move such a large sum to prevent that fraud.

Yes, it's hilarious.

One of my banks requires me to do the transaction over the phone if it's above a certain limit.

At which point, you talk to someone in a call center, and they proceed to ask you exactly the same information which you needed to introduce in their web interface to make the wire transfer yourself, and nothing else.

This includes giving your web interface credentials over the phone, which could be heard by someone inadvertently or even phished if you happened to have misdialed accidentally. Or stolen by the call center employee.

It's also great fun to have to spell out 20+ account digits, the names of the other people/companies, phone numbers and email addresses to receive confirmations and even a description of the transaction (fortunately I don't always buy sex toys).

Gosh, how I love to spell out all this information, digit by digit, letter by letter, over a phone call! But since it's for my protection it makes it OK, right? Right? Hello?


No, you're expected to call and set up an appointment with a banker who can sell you on some kind of business account that has appropriate services for moving money in that way.

And yes, this will cost more and take more time than the spreading-it-out method.


no, this is too cynical. just give them a call, authenticate yourself, and they'll happily raise the limit for you.

maybe if you're moving 50k/week they'll try and get you on a business account, but at that point you're already not using the account for the purposed you claimed when you opened the account.


working around a restriction is called "Structuring" in the US:

https://en.wikipedia.org/wiki/Structuring


This is not true. Structuring is much more narrowly defined, including in that Wikipedia article. It requires you to be working around a legal or regulatory reporting requirement.


Part of the problem is a bank training you on recognizing that they have countless silly obscure rules for their own purposes - for example in what your password may be and how messages to their employees might be (mine limits the messages to be very short - no space to explain anything.) So you are quickly trained to make do with the silly rules. I.E. multiple ACH over several days and move on with your life... Or in the case of messages, I just continue my explanation in multiple messages.

Either way, the bank has trained the customer to work around limits. They can't have it both ways.


And people are surprised why so many were excited to use cryptocurrencies. The current banking system is broken to the root.


And getting progressively more broken, due to increasingly stricter and more numerous laws, and more effective enforcement.

Hell, in Spain you can't even legally pay anything in cash if it costs more than 1,000 EUR. In Greece, the limit is 500 EUR.


> I.E. multiple ACH over several days and move on with your life...

Surely, just picking up the phone and speaking to them is faster and easier than engaging in structural transactions like that.


Is it? Usually no, it's not. At one bank, they want me to always talk to the same person - who is generally competent but also usually not available and sometimes outright on vacation with no warning. At another bank, they want me to go through the basic 800 number - where the person who answers usually knows much less than I do. Picking up the phone is usually not a good solution.


One, this isn’t structuring. Just because you read what structuring is 5m before you read my post doesn’t make this structuring. 50k is way over reporting limits.

And also no it isn’t faster to pick up the phone, even if I don’t get out on hold at all. An ACH transfer takes seconds, it’s like writing a digital check. Doing it 4 times takes very little time.


I didn't mean "structuring" in the legal sense, I meant it in the technical sense (arranging transactions in order to avoid something).

I find it's much easier to engage in a 15 minute phone call than to do multiple transactions over a number of days. You may find it different, of course.


Banks have an incentive to create as many roadblocks as possible to prevent you from transferring out large sums of money.


You may be surprised at how difficult the regulators make life for the banks.

Read this case-study from the UK. https://www.financial-ombudsman.org.uk/decisions-case-studie...

"We thought the spending on Marta’s account was very unusual for her and – after the first few payments – the pattern of transfers from her account should have caused the bank some concern meaning that it ought to have intervened. We thought that if the bank had asked Marta about the transactions she would have told it what she was doing."

Consider the implications of this.

It gets worse, "In deciding fair compensation, we also considered if would be fair for Marta to bear any additional responsibility for what happened. However, as we thought the trading platform and correspondence with the fraudsters was very convincing, we decided against that on the facts of this case. So we asked the bank to refund all the transactions which took place after the point we thought it should have intervened."

This regulator does not respect the concept of personal responsibility.

These problems are also downstream of systematic public policy failure. We have had telephones for about a century. Yet in 2023, it is still routine for pensioners to receive calls from organised fraudsters. There is no reliable way to trace the source of these calls, to block ranges of numbers, to prevent scam call centres, to issue pensioner-friendly forms of telephone with higher safeguards. These problems are not technically difficult to solve. All could be fixed if the telcos behaved responsibly. That work should have been done thirty or more years ago.

Since that work was not done, there is now a fraud crisis. In response, regulators have forced controls to the last point possible, which is with the banks. Huge inefficiencies follow.


Ouch. Marta literally answers a get-rich-quick ad, then installs a program that lets a fraudster remotely control her computer to send money to a bitcoin exchange account that was opened in her own name (requiring her own ID documents to do so), and then send the bitcoins onwards the "investing" platform.

> The CRM Code did not cover this type of transaction, because the payments Marta made from her bank account were sent to an account held in her own name with the crypto exchange. However, outside of the CRM Code, banks have other fraud prevention obligations – including to look out for unusual transactions.

In other words although there's a document saying what a bank should try to do, that is actually meaningless because the regulator believes banks should somehow stop all fraud even in cases where people are literally giving random strangers total control over their bank account, deliberately, because they can't be bothered understanding how to operate their own financial accounts.

The cherry on top:

> If you invest in a firm which isn’t authorised by the FCA, you risk losing your money, without any protection.

Apparently not, because if some civil servant thinks you are pitiable and the scam was convincing, they'll force the bank (i.e. other customers) to make you whole again anyway.


Interesting, thanks for sharing.

This situation creates a market for new fraud-detection products, if anything just so that the banks can tell the regulator that they did their due diligence. Of course it depends on how common situations like Marta's are, and how expensive they are for the banks.


They have those, lots of them. It doesn't matter if the regulator will take a stance like "we think (with the benefit of hindsight) it looked suspicious, so pay up". And unfortunately this is a very common thing for regulators to do. A lot of money laundering fines against big banks are like this. A civil servant comes in five years later after being handed some evidence that some transactions were criminal, says the bank should have known (without explaining how) and levies huge fines or gets a huge settlement.


If you're the largest customer at a small bank they'll be happy to see you move it out because that much money can make them nervous.


Unless they're so small that you taking out your money results in them experiencing liquidity issues.


That's the situation that makes them nervous.


In which case they already have bigger problems.


In particular in the US, they are on the hook for almost all of it if the money was fraudulently moved out.


They'll try to dissuade you even if they know the transaction is legitimate.


Not the banking industry but I had an issue with a leaked Twilio key once and it was a funny conversation like that. They kept telling me that I had been a victim of fraud (long story, a contractor pushed a key to a public GitHub repo). It only took about 7 repetitions for them to finally acknowledge that it was in fact Twilio who had been the victim of fraud: someone, pretending to be me, had asked them to send $1000 worth of Netflix spam and they obliged.

It wasn’t ever really resolved in a satisfactory way but it got to the point where I was so frustrated and tired that I said “fine, we can settle on $200” because it wasn’t really worth pursuing further (based on my hourly rate and how much wasted time I’d already sunk into it)


There are some systems, banking for example, where "hacking" them and trying to be smarter than others can, and actually does, backfire.


"But they don’t tell you what they actually want you to do if you want to move 200k"

They will tell you to use a wire transfer.


Don't know where you live but where I leave this thing is pretty common when you are buying some property. The goal in this case should be pretty obvious.


You do a wire transfer.


Yes, my point is that banks don’t make it clear that maxing out their ACH quotas will get your account frozen and that you should do a wire transfer. You shouldn’t have to learn this the hard way by getting your account frozen (which is very stressful when it happens to you for the first time), and banks should make it clear what you should do, which is my point


Whenever I've been moving amounts at that scale, I've already had a close working relationship with my bank as a natural side-effect of my business activities. As a result, I'd be doing those sorts of transfers by talking to my account manager at the bank.

I suspect that's the norm that banks are expecting.


It's a pretty niche problem though, so I guess not surprising they aren't great about communicating it (it probably was communicated, on page 30 of your agreement in small confusing text).


probably not communicated. Banks usually don't like to say: "your account will totally get frozen if you do this thing up to the limit of what we said you're allowed to do".

They like to keep the impression that account freezes are discretionary not automatic.


Ok with this context I understand what you are getting at.


For which they kindly charge you a fee


schwab doesn't charge a fee to wire from a brokerage account. by the way, there's no minimum balance or fees required to open an account with them. you pick up the phone, get connected with an intelligent person who understands exactly how to help you, and wire the money. usually you don't even wait for an agent.

I'm gonna sound like a shill, but 99% of the problems people are writing about in this thread would be solved by opening an account at schwab. unless you routinely deposit/withdraw large amounts of cash, there's no reason to waste time with other banks.


Thanks - good pointer!


Couldn't you just send a wire?


Yes, but that involves talking to someone and waiting on hold. If there’s no rush, doing 4x ACH is easier, if you don’t know it’ll get you flagged. All I’m saying is banks need to be more prescriptive about telling you “we’ll put a hold on your account if you move large sums without telling us” rather than giving you some fake limit that actually utilizing will raise red flags. This is a common failure mode


I presume the argument some middle management type makes is that exposing their security protocols makes it trivial for a fraudster to work around. Obviously this is a fallacy because any genuine fraudsters has the incentive to work this all out by trial and error, if the information isn't freely available to them on some dark corner of the internet.


Trial and error takes time. Potentially a great deal of time. A motivated fraudster will likely get caught and stopped several times along the way if they're attacking a particular bank.

It's worth bearing in mind that most financially motivated criminals are after easy marks. If you're too hard or expensive to hit, they'll find another target. If you're seeing like a bank, that's a victory and the protocols are doing their job by reducing fraud.


Those typically have huge fees.


$25 to move $50k in an atomic, irreversible way isn't a huge fee IMO. when you're dealing with that amount of money, the risk of it getting frozen or flagged for fraud is > $25. A lot of banks will let you send wires for free if you have a large enough balance.


Not int the context of these amounts.

$20-ish to move 200k safely is nothing. If you are doing it internationally, it's typically tiny compared to the FX cost.


I’d be happier keeping the $25 tyvm.


And risk getting your account frozen "for no reason", really smart.


Sure, write a personal check then and expect a lengthy hold. Or something else on the risk vs. PITA vs. cost framework.

Point is, wires are cheap for what they do. They aren't your only option, but all options have tradeoffs.


This is a debate between sending 4x ACHs over 4 days (presumably from the comfort of your own web browser) vs a wire (often requiring a visit or phone time).


right, and the trade off there is you may get flagged for structuring and locked out, right?

As I said, there is a range of cost/risk/PITA options available. This is niche enough I don't think it's particularly worrying the banks don't support it easier.


What structuring? Both are way over mandatory SAR thresholds.


I've also heard repeatedly in conversation people frequently admit to structuring financial transactions for a variety of reasons, completely unaware that doing so is a felony.


Is it illegal to round up your transaction to $10,001 for the purpose of making the bank file the form so you can't be accused of structuring to avoid it?


(the problem with these ideas is that they make you responsible for knowing all these things - which ideally is what you pay the bank for.)


Does the bank have a human look at / file the form, or is it automatically generated? (Unless they are required to do it manually, I can't imagine they do)


lol, no. Why would it be?


It’s only illegal if you’re intentionally doing it to avoid reporting


They are intentionally doing it because of mostly imagined consequences of having the transactions be reported. And committing a felony as a consequence.


Sorry, what does "structuring financial transactions" mean in this context?



The only way to get any assurance about staying out of trouble with your bank is to have enough money that they start to not care so much about the risk of doing business with you, and to pay a lot of money to an expert to do the AML compliance for you.


The other way is to communicate with the bank. Talk to them. If you're doing something involving a large amount of money, or something unusual for you, call them up, tell them what you're doing and ask for their help.

Don't do everything online. Do the big or unusual stuff person-to-person. It doesn't even have to be an in-person visit. Give them a call.


This is a woefully naive position. Unusual activity on your account is an easy way to get a SAR. Calling up to check whether you’ll get a SAR is an even easier way to get a SAR.


It's always worked very well for me for decades.

I wouldn't ever ask whether or not I'll get an SAR, though. That sort of question is pointless. Instead, I just treat my bank as a core partner to my business and include them in my plans. The side-effect is that nothing I do looks suspicious to them.


CTRs are required for $10,000+. Structuring is more like if you're depositing $9,999, which is kind of the opposite of a round number.


It would also be two deposits of $5k or 10 $1k deposits, etc.


Anecdote: I hade my Revolut account suspended for 24 hours for a reason they refused to disclose yet admitted as their mistake last week


The solution is simple: Stop "banking" with entities that don't have a banking license.


Sometimes you don’t get a choice, especially when only just moving to a new country.


Revolut has a banking license, at least in Europe


In Lithuania. No offense to any Lithuanians reading here, but I do not trust their banking regulators as much as French, German, Dutch, Nordic, etc. Obviously, selecting Lithuania is a clear case of regulatory arbitrage. I still cannot believe people are doing serious business with Revolut. Do you really think the Lithuanian regulators are going to help (catch bad behaviour) during a banking crisis? I have no faith.


I genuinely don’t know where to begin with addressing this level of ignorance. All Central Banks, including the Bank of Lithuania, are governed by the European Central Bank. Passporting works because of an equality principle.

Lithuania has worked hard to become a fintech hub for Europe, and that isn’t based on a poor regulatory regime.

If you can bring actual facts to the table as to why the Lithuania banking license is inferior, we can have a discussion. Now you are just spouting baseless “Lithuania banking license is bad because of Lithuania” nonsense.


How do you explain the 2014 Danske Bank money laundering scandal in Estonia? To be clear: I recognize that Estonia is not Lithuania. My point: Estonia is also a part of EU / Eurozone and its central bank is governed by ECB. That governance did little to nothing to stop the money laundering scandal. It went on for years, which implies incredibly weak enforcement of banking regulations. Outside of the economic majors in EU, I am generally distrustful of banking regulation _enforcement_. Yes, the laws are written, but are they effectively enforced? I doubt it.


I'm ready to believe this, but IIRC on previous posts people accused the poster of doing shady things but I don't remember seeing it ever coming out that they actually did. Do you have some links?


>but eventually it comes out that they’re in North Korea selling cannabis to Iran or something.

I only do this on the occasional Wednesday though when things are quiet at work


This is a little victim blamey. Banks mess up all the time. Regressive policies in capitalist institutions are extremely common. Incompetence is common. Negative action in service of the profit incentive is common.

There's no shortage of people who found their accounts closed for "fraud" who did nothing wrong, but instead were victimized by the algo and the general incompetence of banking tech.

Personal financial experts often tell people to carry a credit card from a bank that isn't yours or have a checking account at a separate bank because this is so common.

Lastly, the people moving money to blacklisted places aren't opening Bank of America checking accounts. There's entire cottage industries and crypto and shady international banks, etc ready to cater to them. They're not getting banned because they use services that don't ban them for moving money around like this. But everyday working class people get banned randomly for moving gifts or tuition money around, etc.


> The people moving money to blacklisted places aren't opening Bank of America checking accounts.

My understanding of money laundering, and the laws designed to catch it, wasn’t that it’s used to get money into illegal places. Laundering is used to get money back out of illegal places in a way they can spend as legal money - exactly a Bank of America account.




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