Reporting suspicious activities: Proposed changes to the AML/CFT Act

Businesses have to tell Police if they notice things that are potential signs of money laundering and terrorist financing. Proposed changes to what you have to report will affect all businesses that currently – or will – have to do this.

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One of the most important ways of preventing and detecting money laundering and terrorist financing is when businesses and professions report information to the Police Financial Intelligence Unit (FIU).

The reports help law enforcement to find out where laundered money comes from, stop crime, prosecute criminals, and seize illegally earned money and assets.

Proposed changes to the Anti-Money Laundering and Countering Financing of Terrorism (AML/CFT) Act would expand the types of things business have to report. Different rules would apply to businesses that deal in expensive goods (known as high-value dealers).

Suspicious transaction reports

If you provide services or carry out transactions covered by the Act, you have to monitor customers’ accounts for suspicious transactions.

As a general rule, suspicious transaction are ones that are inconsistent with a client’s usual activities or what you’d expect for that type of client.

If you notice suspicious transactions, you have to submit a report to the FIU if you have reasonable grounds to suspect it’s relevant to a criminal offence and might help an investigation or prosecution.

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Suspicious activity reports

Changes proposed for Phase 2 of the AML/CFT Act would mean you’d also have to report suspicious activity.

This is because you might notice things that could provide valuable financial intelligence for detecting crime, even if the customer doesn’t make a transaction.

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How do I know if something is suspicious?

The FIU and government agencies that supervise businesses will provide you with guidance and reports to help identify suspicious activity and typical money laundering or terrorist financing ‘red flags’.

Examples of suspicious transactions or activity may be:

  • complex or unusually large transactions that are out of step with what you’d expect from the customer
  • unusual patterns of transactions or activity that have no apparent business or legal purpose
  • any other activity that appears to be related to criminal activity

For more information, see the NZ Police website:

Financial Intelligence Unit (FIU) assessments and reports (external link)

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Prescribed transaction reports

From 1 November 2017, business covered by the AML/CFT Act will have to report ‘prescribed transactions’ to the FIU. This will make it more difficult for criminals to use multiple small transactions, multiple senders or multiple recipients to avoid detection.

Prescribed transactions are:

  • international wire transfers of more than $1000
  • physical cash transactions of more than $10,000

Both Phase 1 and Phase 2 sectors covered by the Act will have to report prescribed transactions.

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What are the rules for businesses that deal in high value goods?

It’s proposed that the obligations above won’t apply to high value dealers.

However, you will have to file reports to the FIU on cash transactions of more than $15,000.

Also, if a customer’s activity is suspicious, you may decide to file a suspicious activity report with the FIU, though this is optional.

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How do I submit a report?

Businesses submit reports to the FIU using goAML, a secure and confidential online tool for exchanging information with the unit.

You need to register for goAML to submit reports. Further information is available at the NZ Police website:

goAML – Financial Intelligence Unit reporting tool (external link)

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