In October 2022 the Financial Markets Authority (FMA) issued a formal warning to InvestNow Saving and Investment Service Limited for failing to comply with the AML/CFT Act.

In the FMA’s view, InvestNow had failed to:

• Conduct and complete standard customer due diligence, including:


1. Obtaining the minimum expected information about the nature and purpose of the proposed business relationship from customers.
2. Taking reasonable steps to complete identity verification of customers and beneficial owners.
3. Conducting when required ongoing and/or enhanced customer due diligence on certain customers, most importantly this included ensuring reasonable steps were taken to verify customers source of wealth or funds.

• Establish, implement and maintain an adequate and effective AML/CFT programme.

The FMA warning also mentioned that they now require InvestNow to complete a number of actions to meet its obligations under the Act in the future.

Unfortunately the areas of concern highlighted in this warning are not uncommon areas that we at Strategi see on a regular basis when conducting independent audits. This highlights that reporting entities must take their audit results seriously, as failure to fix any deficiencies that are highlighted may result in a public warning been issued which can have a detrimental effect on your business. 

If you need help with your AML/CFT compliance programme or just want to check to see if you are on track please feel free to get in touch with the team.