Anti-money Laundering

PwC’s Anti-money Laundering team uses experience and knowledge to help clients stay on the right side of the latest, evolving compliance laws.

Staying on the right side of compliance laws

The first phase of New Zealand’s anti-money-laundering regime came into force on 30 June, 2013. Since then, most financial institutions became "reporting entities" and have been required to comply with the requirements of the Anti-Money Laundering and Countering Financing of Terrorism (AML/CFT) Act 2009. The regime continues to have a significant impact on a wide range of reporting entities, such as banks, finance companies, non-bank deposit takers, as well as many other businesses and their customers.

The AML/CFT regime is evolving, too, with reporting entities obliged to comply with prescribed transaction reporting requirements from 1 November 2017. A number of new non-financial businesses or professionals will become reporting entities as part of the second phase of the act through the AML/CFT Amendment Bill when passed. The bill – expected to be passed in mid-2017 – will redefine reporting entities as:

  • financial institutions
  • casinos
  • lawyers and conveyancers from 1 July 2018*
  • accountants from 1 October 2018*
  • real estate agents from 1 January 2019*
  • trust and company service providers providing certain activities*
  • high-value dealers and the New Zealand Racing Board from 1 July 2019*.

Existing and new reporting entities have a number of steps to complete to be compliant with the requirements of the act. These include completing a risk assessment and developing an AML/CFT programme of policies, procedures and controls.

How PwC can help

PwC has a full AML/CFT service offering led from our Forensic Services practice, designed to assist clients comply with their obligations under the latest acts. Our AML experience is draws from more than a decade of providing comprehensive AML/CFT Advisory and Audit Services, while our expertise comes from our local experience and the decades of AML expertise from the global PwC network.

The anti-money laundering services we’re perhaps best known for include:

  • new reporting entity AML/CFT risk assessment. programme development and implementation solutions
  • risk assessment and programme review and testing
  • remediation of inadequate AML/CFT compliance frameworks (resulting from audit, internal review, or supervisor inspection)
  • investigation of AML/CFT events
  • assistance with money laundering allegations including civil seizure and forfeiture by NZ Police
  • training and workshops (including meeting your programme requirements)
  • AML audit services (performed in line with international assurance standards)
  • pre-supervisor inspection preparation
  • operational effectiveness and internal systems testing
  • know your customer consulting and insights
  • ensuring local AML/CFT requirements are included in client's global programmes where a reporting entity has other jurisdictional or global entity AML/CFT requirements to meet
  • assistance with prescribed transaction reporting requirements (implementation and testing).

*These new "designated non-financial business or profession" reporting entities will be required to comply to the extent that they carry out related activities including acting as a formation agent of legal persons or arrangements, providers of registered office or business address, managing client funds, providing real estate services or conveyancing. Please note this is not a full list of activities.

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Stephen Drain

Partner, Auckland, PwC New Zealand

+64 21 196 2500