The sector supervisors have updated their AML/CFT Programme Guideline. With applicability across all sectors, and a lot of new changes, this is essential reading for all Compliance Officers and compliance staff.

Split into eight parts, the AML/CFT Programme Guideline addresses all areas of your Compliance Programme, from the impacts of ML/TF and proliferation financing, through to customer due diligence, staff vetting and training, to the regularity of your documentation.

We have seen a few key changes to the guidance which will help reporting entities in updating their documentation:

• The sector supervisors have included checklist boxes throughout the guidance. These are inserted into specific points of the guidance, detailing the expectations of the sector supervisors and what reporting entities should consider when updating or writing their Compliance Programme.
• The sector supervisors have also included “supervisor’s view” boxes throughout the guidance, which essentially show the thinking of the sector supervisors.

The insertion of “supervisor’s views” and “checklist” boxes throughout the guidance highlights the expectations of the AML/CFT supervisors.

Additionally, it provides reporting entities guidance on how they should approach their obligations and interpretation of key legislative requirements.

The guidance now addresses the regulation updates for 2023 and 2024, as well as revamping specific sections. Some highlights for AML Solutions were:

• The Guideline addresses the new requirement to risk-rate all new customers from 1 June 2025, along with the sector supervisor’s view on practical implementation. It indicates a flexible but accurate approach is expected. Both manual and automated approaches are deemed appropriate. The guidelines later link a number of wider obligations such as ongoing CDD and wider transaction monitoring to these risk scores.
• The section for ongoing due diligence and account monitoring has been revamped, with a closer link between ongoing CDD and account monitoring detailed in the guidance. Highlights include:
  • Insights to transactions Supervisors consider potentially higher risk including international payments, cash transactions and those just under reporting thresholds.
  • Clear expectations that nature and purpose information need to be linked to transaction monitoring procedures.
  • Insight into Supervisor expectations regarding transaction monitoring:
    • Priority treatment of alerts that flag higher risk activities.
    • Transaction Monitoring system/process effectiveness to be considered including multiple alerts relating to the same transaction, false positive rates etc.
    • Regular review and refinement of rules and triggers, which should align to the reporting entities risk assessment and wider typologies.
  • Clarity that Supervisors do not consider it necessary for reporting entities to review CDD information in the absence of a risk-based reason for low-risk clients. The expiry of an identity document does not trigger a requirement to update a customer’s CDD information. Where a customer’s file is reviewed and it is determined that the CDD information does not require update, this rational should be documented in the customer file.
• Staff vetting and training requirements have been clarified, with an emphasis on use of registers to maintain information on staff vetting and training information.
• Expectations regarding the management of third-party agents are commented on, reminding reporting entities they ultimately remain responsible for any areas of compliance which have been outsourced.
• Emphasis is once again made regarding culture of compliance particularly the tone from the top, through active demonstration of the importance and value of the AML/CFT regime.

 

Dive into these updates in detail by joining our live online workshop on 4th December 1:30pm: AML/CFT Programme Guidance Updates: The Practical Impacts

Our Head of Audit & Consulting, Tijana Misur, will take you through the guidance release, discuss how your compliance programme will need to be updated to reflect the changes, and cover what it means for practical application of AML/CFT in your business.

Tickets are $275 +GST and fees pp and are available on our website here. Invoices are available on request by emailing jessica@amlsolutions.co.nz