Account monitoring for Bookkeepers July 2020

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15 July 2020

Following some feedback from the Institute of Certified NZ Bookkeepers regarding the AML/CFT Act account monitoring obligation, the Department recommends that Bookkeepers refer to this previously published explanatory guidance for Bookkeepers.

Specific to the account monitoring obligation some key points to note include: 

• The account monitoring obligation only applies to activities captured by the AML/CFT Act.  For Bookkeepers, it does not apply to maintaining records of client’s income and expenditure as part of the bookkeeper services provided to clients. 
• The account monitoring obligation applies to the facility or arrangement provided by the reporting entity to the client. In the context of Bookkeepers, this means it applies to the involvement that the bookkeeper has in managing, authorising or processing transactions on behalf of clients. These are captured activities. 
• Customer Due Diligence (CDD) provides knowledge of the client’s business to be able to assess whether instructions and transactions align with their risk profile, and to detect any potentially suspicious activity or transactions.

More information is available on our webpage Information for Accountants and in our published Accountants Guideline (PDF, 1.2MB)