What’s in store for 2019?

Inspections

We can report that the AML/CFT Supervisors have started the year on the front foot, with a number of reporting entities having their documents reviewed and in some cases, these are followed by an on-site inspection to see that the policies and procedures stated in the AML/CFT Programme are being followed. From the feedback received it seems that their focus is on enhanced due diligence i.e. what is the source of funds and wealth.  

All inspections and audits are based on presenting evidence to support your customer due diligence and enhanced due diligence as required by the AML/CFT Act and Codes of Practice. Given this focus we recommend that you regularly review your policies to ensure that you are collecting sufficient information to satisfy requirements.

Audits

It is estimated that there are approximately 8,000 reporting entities and a small number of auditing firms. It is recommended that you book your audit early to avoid not being able to secure an audit within the required timeframe.

Document Review

We recommend that you review your Risk Assessment and AML/CFT Programme to ensure they are up to date and reflect how your business deals with AML/CFT requirements. A version history should be added to each document to record the date of the recent update, a summary of what has been updated and who approved the update. By doing this it demonstrates that you are keeping the documents up to date (at least yearly), which is a requirement of the AML/CFT regime.

Annual AML/CFT Reports

The Annual Report to your AML/CFT Supervisor is due to be lodged by the end of August 2019 for the year ending 30 June 2019. We have published some of the questions you can expect to be asked in this report. Please see – Annual AML/CFT Report