A careful observer could find that the enforcement authorities are actually beefing up their enforcement and composing themselves for more active applications of the AML in the future. Jun Wei (Hogan Lovells)

To date, China’s concentration control rules remain rudimentary compared with their more developed counterparts in the United States and European Union, and uncertainties surrounding the review standards and procedures abound.

This article will discuss certain challenges in implementing the AML given ambiguities and uncertainties that call for special attention.