This is only theory, unfortunately.Quite strange...
Generally, in my experiences with this type of financial institution, you keep the compliance officers on quite a tight leash and have to keep them in line with corporate goals (to make as much money on fees and safeguarding account interest as possible) which is a direct product of leaving your clients alone when possible. You shouldn't put the board into compliance positions, though, it brings in bit too much light 😉
The regulators don't care too much about AML on its own. If you are not doing things too publicly and not giving them a bad name somehow, they will not strike on AML alone. They will use AML deficiencies as a way to increase your fine or grounds for revocation if they are already planning to impose these punishments – it is good for strengthening their position and one can always find issues in AML because there is no fixed model or rulebook.
On the other hand, I think I know more operators who have had the license revoked OR voluntarily relinquished it OR sold the entity than those who still have PI/EMI/CASP to date. EU is not comfortable for doing business in the financial sector and the only saving grace is the central bank access to SEPA clearing.
The reality is that the sector is polluted by monkeys, and things happen randomly. Sometimes you can obtain results with bananas, when you don’t care it’s just randomness.
Plus, many of these EMIs exist just for reasons only known to their owners. Genuine customers are a nuisance.

