Suspicious Activity Reporting vs Customer Relationships
Establish a structurally independent compliance function so SAR decisions are insulated from revenue or relationship pressure.
CyberTRIZ analysis · Regulatory contradiction R134 · one of 8,235 worked contradictions published by CyberTRIZ.AI
Regulations
Contradiction
Resolution
Separate AML reporting decisions from commercial considerations through independent compliance governance.
Evidence
SAR Register
Investigation Reports
AML Procedures
Kpis
SARs submitted
Investigation completion time
Controls that address this (13)
FATF-AML-001 - Implement Risk-Based AML/CFT Approachoperational · critical priority · Implement a risk-based approach to AML/CFT covering: national risk assessment awareness, institutional risk assessment, risk-based allocatioFATF-CDD-001 - Implement FATF-Standard Customer Due Diligenceoperational · critical priority · Apply CDD measures to all customers: identify and verify customer identity, identify beneficial owners, understand the purpose of the busineFATF-R1-001 - Institutional AML/CFT Risk Assessmentgovernance · critical priority · Conduct a comprehensive institutional AML/CFT risk assessment covering: products and services, customer types, delivery channels, and geogra