Thanks - that Tier 2 distinction is exactly where I think legacy risk models misfire. Once capital interacts with shared laundering infrastructure, “normal” flows stop being normal very quickly. The retroactive liability piece is regulators catching up to that reality.
Thanks - that Tier 2 distinction is exactly where I think legacy risk models misfire. Once capital interacts with shared laundering infrastructure, “normal” flows stop being normal very quickly. The retroactive liability piece is regulators catching up to that reality.