Payroll's a very specific purpose, though, and you have a specific relationship with the recipients and probably have more than enough identifying information on your employees to satisfy KYC requirements. It's not the same for AML purposes as sending large amounts of money by wire to people in various locations throughout the world whom you're not paying for goods or services and about whom you have limited information. Banks can and do impose transaction limits on accounts, especially when your business and/or your customers are seen as "high risk".
If you look at the cases where banks and money transmitters have received large fines for non-compliance with AML/KYC requirements, they've always involved large volumes of wire transfers to and from overseas jurisdictions and inadequate verification of identity, origin of funds and destination of funds.
This is pretty much it. There are also some withdrawals which for various reasons need to be handled manually by us before being sent out, and there are only so many transactions that can be carried out by our staff in a given day.
Can you explain? I am trying to imagine it.
I'm trying to put myself in the seat of someone who doesn't have the luxury of sending an Excel spreadsheet to the bank and saying "please wire all this money", but nevertheles has all the information of the money he'd
like to wire on my screen in front of him.
What does the bank want to be satisfied that I know who my customer is? Why couldn't I take that same spreadsheet, print it out, and then print copies of all the passports, driver's licenses, and all the other stuff they would want as proof I know who I'm sending my wire to. Then on each sheet of ID documentation, I would hand-write which wire it belongs to, for easy cross referencing. I would take it to the bank and say - here ya go - please let me know if any of this isn't enough.
I would imagine this would be limited mainly by how quickly I could sit and print people's documentation, but I can't imagine it would take me weeks where, for example, someone trying to pull $10k would have to wait a month.
And meanwhile, I would be able to safely report to my customer, "Yep, we submitted the wire request to the bank on
and that's where it's at!"... if the bank takes 8 months to deliver the wire, that's the customer's problem with the bank, no longer MtGox's problem, as MtGox will have performed as instructed.
Now, if the banks dislike Gox's wire activity or something, that would be understandable... but this was not stated in the OP, which discusses problems with Dwolla.