The Subtle Distinction Between “Evading” and “Avoiding” Is Key to Determining Whether the Obligation to File a Suspicious Activity Report Exists

Brendan R. Kelly, CAMS

As the volume of structuring-related SARs continues to increase and demand additional resources, the need to limit unmeritorious filings becomes even more critical. With a focus on a particular subset of customer behavior, this paper examines the relevant issues at play, the challenges that AML Investigators may face, and highlights an often-overlooked distinction that can determine whether the behavior is innocuous or warrants a SAR.

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