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

This guide highlights common weaknesses identified during AML/CFT supervisory reviews and helps firms identify areas where their framework may require attention.