The New Zealand Financial Intelligence Unit (FIU) has released the 2024 National Risk Assessment (NRA), the first update since 2019. This document outlines the current risks related to money laundering (ML), terrorism financing (TF), and proliferation financing (PF) in New Zealand. As a reporting entity under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT Act), you should review this update to ensure your risk assessment and compliance measures remain up to date.

Why timely audits matter

AML/CFT audits are required under Section 59 of the AML/CFT Act, and supervisors take them seriously. An overdue audit can raise red flags and lead to further scrutiny. Completing audits on time shows AML supervisors that you are proactive about compliance and risk management.

You can access the full NRA here: FIU 2024 NRA

Key updates in the 2024 NRA

• Virtual asset service providers (VASPs): The NRA now includes a section on VASPs, highlighting the increasing risks associated with virtual assets and their potential use in ML and TF. Entities working with virtual assets should review their controls accordingly.
• Proliferation financing risk assessment: The FIU has assessed the risks related to funding activities that support the proliferation of weapons of mass destruction. This is a new addition, and reporting entities should consider how this risk affects their operations.
• Changes in criminal behaviour: The report updates the understanding of how criminals generate illicit income and exploit financial systems. This information is useful for refining risk assessments and improving detection measures.

How to respond to supervisor requests

When responding to FMA or DIA requests, ensure you:

• Respond promptly: Meet deadlines and submit all requested documents on time.
• Be transparent: If your audit identified deficiencies, provide a clear explanation of the corrective actions taken or planned.
• Provide a plan: If there are ongoing issues, outline steps and timeframes for resolution.

What reporting entities need to do

• Review and update risk assessments: Compare your existing risk assessment with the new NRA findings and make necessary updates to reflect emerging risks.
• Update AML/CFT programmes: Adjust policies, procedures, and transaction monitoring to address any newly identified risks, especially those related to VASPs and proliferation financing.
• Staff training: Ensure your team understands the latest risks and is equipped to identify suspicious activity.
• Engage with regulators: Stay in touch with your AML/CFT supervisor to ensure your compliance efforts align with expectations.
• Monitor legislative changes: Keep an eye on potential amendments to the AML/CFT Act, which may further shape your obligations.

Next steps
Take the time to read the 2024 NRA and ensure your organisation’s risk assessment and AML/CFT Programme reflect the latest insights. If you have any questions or need guidance on how to implement changes, reach out for support.

Also, don’t forget to attend our upcoming general refresher training webinar, where we will cover key updates, including the implications of the new NRA