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When it comes to AML/CFT conferences the presentation given by Dr Fiona Swee-Lee Price at the 2021 FIU / ACAMS Conference was unique. At first glance a presentation on how someone’s name is so critical to an investigation seemed like ‘Investigations 101’. In fact, it turned out to be one of the most interesting presentations of the conference.

Are advisers a doomed breed and will we see a massive exodus of advisers before the end of the two-year transition period? We don’t think so and here’s why…

As we all try and finish 2021 with a bang, now is a good time to reflect on some of the biggest stories and learnings regarding AML. We’ve handpicked 5 articles which we think are worth revisiting.

All reporting entities supervised by the Financial Markets Authority (FMA) must regularly carry out an individual risk assessment of their business under section 58 of the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT Act).

Making annual predications are fraught with danger as so many things can derail the logical thought process. However, as many Strategi clients are busy with their annual business planning we’ve outlined 10 items that we think you should consider:

As we begin a new year in trying circumstances, it is timely to remind you that the supervisors have expectations that 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 start the year with a bang.

As the largest AML auditor in New Zealand, we have noticed that more and more reporting entities are outsourcing their customer due diligence (CDD) obligations to specialist third-party providers. While this has become the norm, it is important to note that the third-party provider is not a reporting entity and is acting as your agent (as defined by section 34 of the AML/CFT Act).

The Department of Internal Affairs (DIA) reported back in March 2021 that a formal warning was issued to Property Brokers Limited for failing to meet its responsibilities under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009.

“This finding was also made in your last audit” is a comment that appears all too frequently in audit reports for both Phase 1 and 2 reporting entities. It is also a potential red flag for AML supervisors, who indicated several times last year that they will be ramping up enforcement activities for non-compliance.

Both the Department of Internal Affairs (DIA) and the Financial Markets Authority (FMA) have the power to conduct desk-based reviews and onsite inspections to assess whether a reporting entity’s risk assessment, AML/CFT procedures and policies meet the minimum requirements as set out in sections 56-60 of the Act.