What good looks like
25 October 2022
AML/CFT Regulators from the Department recently completed an on-site inspection of a Law Firm in Auckland.
While the visit was targeted, our regulators found this Law Firm was actually largely compliant with their obligations under the Act. This is positive with the Law Firm having had no previous engagement with the Department.
What good looks like:
- Supervisor guidance had been utilised to ensure appropriate practice.
- Feedback from their Independent Audit had been taken on board and remediated.
- Well-rounded understanding of customers and countries dealt with alongside the associated risks to these countries.
- Compliance Programme and Risk Assessment material is clear, adequate and in line with the expectations of the AML/CFT Act.
- Understands and can explain the differences between Customer Due Diligence and at appropriate times going above and beyond what is required under the Act, such as completing Customer Due Diligence on clients who aren't captured.
While there were some areas for improvement, our AML/CFT Regulators found the firms understanding of the AML/CFT Act overall was sufficient. This on-site inspection was in contrast to what our AML/CFT Regulators have recently discovered in the regions as part of their wider inspection work.
