> It’s not a shadow government if the laws and policy are public. You can read all of the laws.
This is not really true. The BSA says banks have to maintain an "adequate AML program" and policies to "reasonably know your customers identities" or whatever. These policies are deliberately vague. Then based on these deliberately vague rules, banks have to make a compliance program that usually goes above and beyond the minimum that is required (in order to avoid being fined). These compliance programs that specify what kinds of behavior and transactions to consider risky are never made public.
This is not really true. The BSA says banks have to maintain an "adequate AML program" and policies to "reasonably know your customers identities" or whatever. These policies are deliberately vague. Then based on these deliberately vague rules, banks have to make a compliance program that usually goes above and beyond the minimum that is required (in order to avoid being fined). These compliance programs that specify what kinds of behavior and transactions to consider risky are never made public.