Years ago I attended a conference that had a "fireside chat" with a DoJ official on the topic of these types of ransom payments. He framed the issue as being similar to kidnapping ransoms: When an American is taken hostage each family is inclined to make payment but it fosters an industry around kidnapping Americans. Congress put a stop to it by making it illegal to pay the kidnappers. The industry shifted by ceasing…
How is it not a violation of AML laws to pay a ransom like this? Surely they didn't verify that the recipient (a criminal) isn't sanctioned or associated with sanctioned organizations.
KYC is a tool to prevent money laundry and it's typically an obligation of financial institutions. Sending money to an anonymous (to you) recipient is generally not a KYC violation if you are not in the money transmitting business and you aren't doing the payment on behalf of someone else.
There are infinite shades of gray in this topic, of course, but I can't see AML being relevant in this particular case.