KYC policies are causing nervousness within banks. Half of the anxiety is caused by regulators and the other half by customers.
First, there are the regulatory frameworks. FDIC and OCC guidance is constantly changing. Enforcement varies from month to month. Operation Chokepoint ebbs, flows, and ebbs again.
Second, there’s the nature of today’s customer base. New business entities are replacing old ones with a twist on the old proverb, “no history is good history.” Further, customers are increasingly cross-border, global actors.