Defensive SAR Filing: An Unnecessarily Heavy Burden on the AML Field

Zhang Teng

Filing a SAR to avoid regulatory criticism is commonly called “defensive filing.” The efficiency and effectiveness of SARs are currently way below the expectation of AML society, as much of the effort is wasted on filing and investigating SARs merely for compliance concerns. The purpose of this paper is to perform a comprehensive analysis of defensive filing and promote effective countermeasures.

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