In October 2024, the AML/CFT supervisors—Department of Internal Affairs, Financial Markets Authority, and Reserve Bank of New Zealand—released an updated AML/CFT Programme Guideline following a comprehensive review. This new guideline provides valuable insights into what the supervisors are wanting to see in AML/CFT Programmes. Strategi Compliance has distilled the 52-page guideline into a one-page summary of actionable steps to help you stay compliant.

Action points:

• Read the new guideline in full if you’re the AML/CFT Compliance Officer.

• Create a checklist based on the minimum requirements of s57 of the AML/CFT Act 2009. Add detailed requirements from the guideline. Review your current programme against each point and mark it as compliant (yes), non-compliant (no), or partially compliant. Note any changes needed. Have a knowledgeable AML/CFT professional cross-check your assessment.

• Amend your AML/CFT Programme using track changes to incorporate the necessary updates.

• Present the updated AML/CFT Programme and checklist to senior managers and directors for approval. Completion of the checklist enables senior managers and directors to have confidence that appropriate analysis resulting in the new version has been undertaken.

• Review and update your Risk Assessment to align with the changes in your AML/CFT Programme.

• Pay attention to key terms in the guideline (p.5), including ‘Reasonable steps,’ ‘Material change,’ ‘Risk-based approach,’ and ‘According to the level of risk.’ Understanding these terms is crucial to tailoring your AML/CFT Programme to your business.

• Use additional guidance like the National Risk Assessment, FIU materials, sector risk assessments, and updated guidelines from supervisors (seven have been issued since April 2024).

• Update your training based on your checklist and ensure all staff, senior managers, and directors involved in AML/CFT activities are trained. Keep records of this training for audit purposes.

Need help?

If all of this feels like a lot to manage, you’re not alone. Strategi can take the load off by updating your Risk Assessment and AML/CFT Programme to ensure full compliance with the latest guidelines. Our team of experts can handle the heavy lifting, so you can focus on running your business. We also offer tailored training modules, including the AML/CFT Compliance Officer (Micro-credential) course, to keep your team and leadership fully informed and compliant. Contact us to find out how we can simplify your compliance process and save you time.