• AML/CFT Health Check - New Zealand Template

    The AML/CFT Health Check Tool has been customised to meet the requirements specified in the AML/CFT Act 2009 for New Zealand reporting entities.

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AML/CFT Health Check – New Zealand Template

The AML/CFT Health Check Tool has been customised to meet the requirements specified in the AML/CFT Act 2009 for New Zealand reporting entities.

Our subject matter experts have leveraged and expanded upon the guidance provided in the AML/CFT Act 2009, as well as, guidance published by the three New Zealand AML/CFT Regulators (Reserve Bank of New Zealand, Financial Markets Authority and the Department of Internal Affairs).

The AML/CFT Health Check for New Zealand reporting entities contains over 350 out-of-the-box questions, comprising AML/CFT requirements, as well as, best practice questions across the following categories:

Customer Due Diligence

  • Customer Due Diligence
  • Reliance on risk assessment when establishing level of risk
  • Basis for verifying identity

Standard Customer Due Diligence

  • Circumstances when Standard Customer Due Diligence applies
  • Standard Customer Due Diligence – identity requirements
  • Standard Customer Due Diligence – verification of identity requirements
  • Standard Customer Due Diligence – other requirements

Simplified Customer Due Diligence

  • Circumstances when Simplified Customer Due Diligence applies
  • Simplified Customer Due Diligence – identity requirements
  • Simplified Customer Due Diligence – verification of identity requirements
  • Simplified Customer Due Diligence – other requirements

Enhanced Customer Due Diligence

  • Circumstances when Enhanced Customer Due Diligence applies
  • Enhanced Customer Due Diligence – identity requirements
  • Enhanced Customer Due Diligence – verification of identity requirements
  • Enhanced Customer Due Diligence – other requirements
  • Politically Exposed Persons (PEPs)
  • Wire Transfers – identity requirements
  • Wire Transfers – verification of identity requirements
  • Correspondent Banking Relationships (provision of banking services by one FI (correspondent) to another FI (respondent)
  • New or developing technologies, or products that might favour anonymity
  • Ongoing customer due diligence and account monitoring
  • Reliance on third parties
  • Prohibitions

Suspicious Transaction Reports

  • Reporting entities to report suspicious transaction
  • Nature of suspicious transaction report
  • Privileged Communication Defined
  • Auditors may report suspicious transactions
  • Protection of persons reporting suspicious transactions
  • Immunity from liability for disclosure of information relating to money laundering transactions
  • Disclosure of information relating to suspicious transaction reports
  • Disclosure of information in proceedings
  • Disclosure of personal information relating to employees or senior managers

Record Keeping

  • Obligation to keep transaction records
  • Obligation to keep identity and verification records
  • Obligation to keep other records
  • How records are to be kept
  • When records must be kept
  • Destruction of records

Compliance with AML/CFT Obligations

  • Reporting entity must have AML/CFT programme and AML/CFT compliance officer
  • Minimum requirements for an AML/CFT programme:
  • Vetting (Employment Screening) –  Senior Mgrs., AML/CFT Compliance Officers and other employee that is engaged in AML/CFT
  • Training on AML/CFT matters – Senior Mgrs., AML/CFT Compliance Officers and other employee that is engaged in AML/CFT
  • Other minimum requirements of AML/CFT programmes
  • Risk assessment
  • Review and audit of risk assessment and AML/CFT programme
  • Annual AML/CFT Report
  • Reporting entities to ensure that branches and subsidiaries comply with AML/CFT requirements

Based on guidance developed by

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