alt Hacker NewsHow exactly would this fall into the purview of AML? As far as sanctions go the burden of proof would be on the government to prove the money went to a sanctioned entity and Instructure isn't a bank subject to KYC requirements.
How exactly would this fall into the purview of AML? As far as sanctions go the burden of proof would be on the government to prove the money went to a sanctioned entity and Instructure isn't a bank subject to KYC requirements.
All my corporate AML training says that not performing some KYC for large payments, directly or through a bank, is a crime in its own even if the recipient isn't sanctioned.
From Claude, maybe it's a little nuanced compared to conservative corporate policies, but doesn't feel very legal: "You can be charged with money laundering (18 USC 1956/1957 in the US, equivalents elsewhere) if you knowingly — or with willful blindness — process proceeds of crime. "I didn't ask" is not a defense if the circumstances were suspicious; deliberately avoiding KYC to preserve deniability is exactly what willful blindness doctrine targets. The recipient doesn't need to be formally sanctioned; the funds just need to be tainted."