Relief during COVID-19 Alert Levels - Independent Audit

AML/CFT Supervisors have confirmed that no adverse compliance action will be taken if reporting entities have acted in good faith. The information that follows is that published by the Department of Internal Affairs and the Financial Markets Authority which should be read so you are aware of your obligations:

Department of Internal Affiars

24 April 2020

Relief during COVID-19 Alert Levels - Independent Audit

This announcement is for reporting entities supervised by the Department of Internal Affairs not able to complete their first independent audit on time due to COVID-19 Alert Levels.

This applies to law firms, conveyancers, accounting practices, real estate agents and some trust and company service providers. These designated non-financial businesses or professions (DNFBPs) have their first independent audit due in 2020.

The Department confirms that no adverse compliance action will be taken against any DNFBP not able to complete its first independent audit by the relevant deadline, providing they have acted in good faith. Reporting entities should be able to explain how COVID-19 affected their ability to complete their audit and be able to demonstrate steps taken to do so upon lifting of Alert Levels.

The independent audit must be completed as soon as practicable in the circumstances.

We also note that some reporting entities, where relevant staff and auditors are working remotely and have access to all required documents, may be unaffected. These entities should complete their audits by the current deadline. 

Financial Markets Authority

21 April 2020

Impact of COVID-19 on independent AML/CFT audits

Section 59(2) of the AML/CFT Act requires a reporting entity to have its risk assessment and AML/CFT programme independently audited every two years. COVID-19 may impact a reporting entity’s ability to have its independent audit undertaken within that timeframe.  Any reporting entity unable to complete its independent audit on time due to COVID-19 should contact the FMA (at aml@fma.govt.nz) to discuss their position.

We will consider each reporting entity’s circumstances on a case-by-case basis, with a view to granting targeted relief where appropriate.