>At the same time, AML solutions tend to be a closely guarded black box which simply tells you to block a customer, finding out why is pretty difficult.

For a good reason! You, as a rule, really don't want to tell the customer why you're blocking them. What will happen in the end is that you will be facing federal charges for assisting the money launderers because you kept telling them what they're doing wrong.

> The laws against that are very strict, incentivizing companies to overshoot and block false positives.

Yes, in many countries they are, but I don't think the laws are dictating Apple to completely turn off the accounts, but instead dictate that Apple should take measures against it.

They could disable those gift card features + Apple wallet/pay if they suspect fraud, and if no one complains within a month, then disable the entire account, rather than start with disabling the account. Would give them space/time to investigate, and wouldn't be a huge pain in the ass when the inevitable false-positives happen, like in this case.

Ironically, I had Amazon flag and undo some gift card purchases (of cards, not with cards) that I made for Christmas, while myself thinking about this category of problem, about why cards are a mechanism for scams rather than specifically money laundering.

The cards were to family members that I normally send gift cards to at Christmas, and the activity was counted as "sus" even though I was asked to validate my card number and expiration date before being allowed to make the purchase.

> The laws against that are very strict, incentivizing companies to overshoot and block false positives.

On that note[1] is a good read (Cmd+F: "suspicious activity report"), although this specific case is about gift cards, but the AML/T&S etc. space is remarkably similar.

[1] https://www.bitsaboutmoney.com/archive/debanking-and-debunki...

AML = ?

(edit) Ah, right, anti-money-laundering, found it in your last sentence.