If you fall into this category, you are required to comply with the following requirements of the AML/CFT Act:

• Report a suspicious activity involving a relevant tax transfer;
• Keep reports of suspicious activities;
• Conduct enhanced customer due diligence after becoming aware that they must report suspicious activity; and
• Conduct enhanced customer due diligence if a customer seeks to conduct a complex, unusually large tax transfer or unusual pattern of tax transfers that have no apparent economic or lawful purpose, or when a reporting entity considers that the level of risk involved is such that enhanced due diligence should apply to a particular situation.

If the only reason you were captured under the act was because you completed these types of transfers, then from the date that the exemption was granted you are NO longer required to:

• Keep a current risk assessment or programme;
• File an annual AML/CFT report; or
• Complete an independent audit at least every three years. 

Note:  If you are providing any other captured activity e.g. providing a registered office or a business address for any client then you are not exempt from the three points above. If you require any clarification, please contact our friendly AML team.