I'll leave that discussion to the courts and café lawyers. I have my own opinions but they aren't relevant to the practical application of an AML program within an institution nor are they appropriate for interpretation of regulatory expectations.
A discussion may not be appropriate for practical applications, but it is relevant in raising awareness and creating a discourse. If thats not something you want to engage in I understand.
oh I'm happy to discuss... just not on social media or in any other public setting. if this were an anonymous account... but it isn't though. cheers, friend. I am reachable if you look for me.