New Zealand’s proposed AML/CFT infringement regime will introduce significant fines for failing to meet fundamental compliance obligations. Reporting entities will have greater flexibility to apply a risk based approach, but where the basics are not done, the message is clear: comply or cop the fine.

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

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.