Start the year with an AML compliance bang!
Start the year with an AML compliance bang!
19 JAN 2023
As another compliance year is upon us, it is a timely reminder that the supervisors have expectations that your core AML/CFT documents are reviewed at least annually.
In most cases (unless your business has changed substantially) there will more than likely be no update required. However as has been the case since the start of the new AML/CFT regime, the supervisors regularly issue new or updated information that will need to be reviewed and may subsequently require you to update your risk assessment and/or programme.
We have outlined a 3-step process to help you work out if any updates are required.
STEP 1
Reacquaint yourself with the documents listed below. These documents outline the national money laundering and terrorist financing risks as well as the inherent risks that your specific sector will face in 2023.
It is expected that your AML/CFT risk assessment document will discuss all inherent risks as outlined in these documents. Once identified and discussed, it is important each risk is given a risk assessment indicator – usually low, medium or high. The outcome of your risk assessment will then determine your approach by way of developing your AML policies, processes and controls.
1. National risk assessment (NZ Police)
https://www.police.govt.nz/sit...
2. Sector risk assessments
DIA – Phase 1 entities Sector risk assessment
https://www.dia.govt.nz/diaweb...
DIA – Phase 2 entities Sector risk assessment
https://www.dia.govt.nz/diaweb...
FMA – Sector risk assessment
https://www.fma.govt.nz/assets...
STEP 2
Ensure you are aware of all media releases issued by your AML supervisor throughout the year. You can do this either by subscribing to updates or regularly checking the news feed on the supervisor’s website as this will usually capture all communications that require actions or updates to be completed.
STEP 3
Review and test all of the processes contained in your AML/CFT programme. This will help ensure your programme is not only fit for purpose but is also effective in doing what it says it will do. It is also important the outcomes of your control checking are recorded in writing.
If you have any questions or concerns, please do not hesitate to contact the friendly team here at Strategi.