Good AML/CFT is not simply about following rules. It is about understanding the story behind the money and exercising professional judgement. This article reflects on why source of funds, source of wealth, beneficial ownership and ongoing monitoring matter in practice, and why the most important question is often not, “Does this person look suspicious?” but “Do I understand the story behind the money?”

ASB has been ordered to pay $6.731 million, the largest AML/CFT penalty imposed in New Zealand to date, after admitting seven breaches of the AML/CFT Act. Much of the media coverage has understandably focused on the size of the penalty and the billions of dollars in transactions involved. However, for AML practitioners, the more important lesson lies elsewhere. The Court found that ASB's AML/CFT programme and transaction monitoring systems were inadequate for a prolonged peri

The AML/CFT reforms point to a more practical and proportionate regime, with greater emphasis on applying the right level of due diligence to the risks identified.

DIA’s enforcement history shows that AML/CFT breaches in the legal sector are not hypothetical. Foster & Milroy, Kidd Legal and PSB each provide a clear reminder that law firms must be able to show more than AML/CFT documents. They must be able to evidence that their risk assessment and compliance programme are current, understood, followed and working in practice.

A Hamilton law firm’s $60,000 AML/CFT fine carries a wider warning for the legal sector. The Foster & Milroy case is a reminder that AML/CFT compliance must be current, evidenced and operating in practice, not just sitting on paper.