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> sexual exploitation, human trafficking, modern day slavery, organ trafficking, high value thefts (petrol, or digits bank robberies), standard social engineering scams etc

That kind of logic can be used to justify putting government cameras and microphones inside everyone's homes too.




Yes, but that doesn't mean that going to the very opposite extreme is the right response. Nobody is itching to emigrate to Somalia.


Having laws requiring the state to get a warrant from a court to conduct a search, is not an extreme. Instituting warrantless mass-surveillance, like monitoring every transaction above a certain size, is the extreme.


You’re not wrong. There’s clearly a balance to be made, but financial institutions are good choke point for detecting and preventing a great number of different crimes. After all few engage in criminal behaviour just for fun, without the profit motive most serious crimes just wouldn’t be worth it.

I don’t advocate for wholesale financial surveillance, and I certainly think the rules advocated by FinCEN here are both naive and an overreach.

But I do think banks should have an obligation to detect, prevent and report financial crime, if only to make sure banks don’t become complicit. Providing financial services to criminals is incredibly lucrative, far more than providing services to ordinary consumers.




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