ASB agreed to pay a $6.7 million civil penalty after admitting breaches of the AML/CFT Act, in a case that was widely reported in December.
The reporting made it clear that the issues were not about missing policies, but about how ASB’s AML/CFT systems and controls operated in practice. The failures related to customer due diligence and ongoing monitoring – specifically whether customer information remained current, whether risk changes were identified, and whether monitoring was properly informed by assessed risk.
For reporting entities, this case reinforces where regulators are focusing. AML/CFT compliance is judged on outcomes, not intentions. Businesses are expected to be able to show that:
- Customer due diligence is kept up to date and refreshed when risk changes.
- Risk assessments actively drive monitoring and review activity.
- Issues are identified, escalated, and addressed in a timely and documented way.
If this case prompts you to question whether your own systems and controls are operating as intended, or whether you could clearly demonstrate this if reviewed, our team is happy to have a no-obligation conversation about your current framework and where to focus.
Read one example of the coverage here: ASB agrees to $6.7m penalty for AML/CFT rule breaches (RNZ).