The purpose of having a robust risk based regime is to ensure that businesses take appropriate measures to guard against money laundering and terrorism financing.
This protects the reputation of individual businesses and New Zealand. But, it also safeguards against identity theft and the victimisation of individuals.
Most reporting entities have got their onboarding processes streamlined now – but it is time to make sure that your ongoing customer due diligence practices are up to scratch.
You must conduct ongoing CDD on existing customers and should be reviewing the details you have on record systematically. This requires you to ensure that the business relationship, including the activities and transactions within it, are consistent with your knowledge about the customer, their business and risk profile.
Ongoing CDD allows you to gain an ongoing image of your customers. Allowing you the chance to detect any material changes, suspicious activities, and transactions.
Rightly stated by the New Zealand Law Society “you cannot adopt a ‘set and forget’ approach”.
Launderers continuously adapt to avoid detection and circumvent preventative measures.
Reporting entities must conduct relevant CDD in the context of their relationship with the customer.
You must file a report with the Financial Intelligence Unit via their goAML online reporting tool within 72 hours of a suspicion forming.
Time is of the essence, make sure you file as quickly as you can and with as much detail as you have available.
Want to know more about customer due diligence? Read our ‘complete guide to understanding customer due diligence‘ or find out when EDD is required in ‘the essential guide to enhanced customer due diligence in NZ‘.
