To get off Basel for a while – Senator Ellison has announced that the AML bill will be delayed until at least mid-June. The longer this goes on the more changes we can expect from the White Paper and therefore the more consultation will be needed when it comes out.
There will be a few big issues here – for the banks' customers the most visible change will be how they have to identify themselves to the bank and whether they need to re-identify themselves at some stage. For the banks, the big issue will be an IT one – how to identify when a customer's behavior changes in a suspicious way.
The additional effort at the front end to identify customers may actually be useful for the incumbent banks and I would suspect that they will try to make the initial process as long as necessary. This is for two reasons – the more difficult it is the more unlikely a customer will seek to change banks and, secondly the more an extensive branch network is worth.
The IT issue is also good for the bigger banks. They will be better able to afford the sorts of software that makes this possible and wil be better able to use the resulting data for marketing purposes.
The really small institutions will not be affected in a major way, but the worry is in the mid-range. I would suggest that CUSCAL or perhaps a software vendor (DataAction, perhaps) will need to take up the running on this if they want to ensure a viable mid range of institutions.