Anti-Money Laundering – critical compliance date looms


All reporting entities must file their first annual Anti-Money Laundering and Countering Financing of Terrorism report before 30 August 2014.

The Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT) requires all “reporting entities” to file their first annual AML/CFT report (on their risk assessment and compliance programme) by 30 August 2014. This date is now fast approaching and we fully recommend compliance with this deadline for your organisation.

Determining whether you are a Reporting Entity under the AML/CFT regime and who your supervisor is will depend on what type of business you carry out:

  • The Reserve Bank of New Zealand supervises banks, life insurers, and non-bank deposit takers.
  • The Financial Markets Authority supervises issuers of securities, trustee companies, futures dealers, collective investment schemes, brokers, and financial advisers.
  • The Department of Internal Affairs supervises non-deposit taking lenders, casinos, money changers and other reporting entities not supervised by the Reserve Bank or the Financial Markets Authority.

The first report is for the period from 1 July 2013 to 30 June 2014. The report requires your entity to provide answers in the following areas:

  • Part 1 - Business contact details and organisation structure
  • Part 2 - AML/CFT risk assessment and AML/CFT programme
  • Part 3 - Products and services, customer and channels
  • Part 4 – AML/CFT supervisor specific questions
  • Part 5 – Compliance with exemptions

The form of the required report is set out in the AML/CFT (Requirements and Compliance) Regulations 2011. However to make this process easier, each AML/CFT supervisor has published a “User Guide” and a template form of report to be used:

Reserve Bank

Financial Markets Authority

Department of Internal Affairs

All annual reports must be filed using the upload facility on the respective AML supervisor’s website. Failure to submit an annual report by 30 August may result in compliance action being taken by the relevant AML/CFT supervisor.

Please do not hesitate to contact our banking team for assistance if you are unsure of your obligations.

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