Suspicious activity reporting in the United Kingdom and the United States: statutory obligations of auditors and optimal harvesting of information

What is it about?

The US anti money laundering regime accommodates the exercise of professional judgment by auditors in reporting suspicions of money laundering. In contrast, in the UK auditors are mandated to report all suspicions, however trivial. The latter approach results in significant defensive filing of suspicious activity reports with low evidential content. The former approach is overseen by a proactive judiciary and constitutional protection of the client confidentiality principle, which does not apply in the UK.

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