Anti-money laundering regulations now in force and changes are beginning to happen.  So, how will AML affect you?

LAST MONTH we reported that Chartered Accountants must become compliant under Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (the Act).

This obligation commences on 1 October 2018 and we are currently preparing a risk assessment for RSM New Zealand.  This will be followed by introducing a programme that we must comply with, including reporting protocols to our supervisor, the Department of internal Affairs.

The areas of risk that we have identified are the following captured activities:

  • Incorporating companies for clients
  • Being, or arranging a person to be a Trustee of your Trust, or a Director or Shareholder of your company
  • Providing an address for your company.
  • Managing your funds in our Trust Account, your bank account, securities or other assets.
  • Engaging in, or giving instructions on behalf of a client to another person, for a range of specified services either as your agent, or in our capacity as Trustee of your Trust or Director of your Company.

These captured activities are at the core of the services we offer and will continue to offer clients.

Once we have identified the risks we face, we will instigate a programme to manage and mitigate them. Our efforts will be proportionate to the risk identified and how to appropriately manage the risk within the scope of the Act.

As we have reported earlier, we will need to conduct Customer Due Diligence (CDD) on new and existing clients, and maintain records on that process.

You will have already encountered CDD that your Bank and Lawyer will have imposed on you, both already compliant with the Act. Our approach to compliance of the Act will be similar and hopefully not too imposing on you.

As we move towards 1 October 2018 we will report further on the process of compliance, which will include finalising our risk assessment, our programme and a comprehensive training day for the RSM New Zealand team.

read our earlier article here