New Zealand is a great place to do business. And we all want to keep it that way.

That’s exactly why, in 2013, the Government brought the Anti-Money Laundering and Countering Financing of Terrorism Act into full force.

New Zealand’s AML/CFT Act, specifically designed to protect New Zealander’s against the threat of money laundering and terrorist financing (ML/TF), requires that all Reporting Entities complete an independent audit every two years.

These audits systematically check that the Reporting Entity’s AML/CFT Risk Assessment and Programme are functioning effectively and that the policies and procedures in place are addressing the ML/TF risks specific to its business.

This may include consideration of whether controls for vetting, AML/CFT training, record-keeping, reporting of suspicious activities, customer due diligence requirements, and other regulations are being fulfilled, for example. It may also include an examination of whether the measures in place are based on the entity’s Risk Assessment, and whether these measures are being followed, not just in theory, but in practice.

These audits play a huge role in New Zealand’s overall AML/CFT regime. Given that the DIA, FMA, and Reserve Bank of New Zealand (who manage the ACT and supervise Reporting Entities) don’t have the time or resources to audit every single business, these auditing obligations instead fall on every reporting entity nationwide.

This independent audit is separate from the Reporting Entity’s own internal review of their AML/CFT Risk Assessment and Programme.

The outcome of the independent audit is a written report on:

• whether the minimum requirements of the AML/CFT Risk Assessment and Programme are being met, and whether that Programme is adequate and effective
• whether there are any weaknesses in systems and processes
• which areas have the highest priority for improvement
• whether any changes are required
• recommendations for rectifying non-compliance

These independent audits, and the resultant report, for Accounting and Book-Keeping businesses, were due recently – on the 30th of September. Although there is some flexibility for entities who were adversely affected by Covid-19, it’s best sorted sooner rather than later, so any non-compliance issues can be resolved.

The Act stipulates that these audits must be undertaken by someone completely independent of the entity, who has not been involved in the development, implementation, or maintenance of the AML/CFT Programme.

This person must have the relevant skills, experience, and knowledge of the AML/CFT Act and Regulations, and have an appropriate qualification to prove it.

Some sectors may be able to meet their obligations through reciprocal audit arrangements between two auditors. However, Chartered Accountants cannot enter into such an arrangement, as this would breach their professional obligations.

Entities may also choose to appoint an external firm to undertake the audit from a fresh and impartial perspective.

That’s exactly where we come in – One AML is a fully qualified independent AML/CFT audit firm that can assist any Reporting Entity with the completion of their AML/CFT audit and the fulfilment of their obligations.

So, if you’re an Accounting or Book-Keeping business who would like professional and specialised assistance in completing your audit, get in touch today.

Our highly experienced team can verify the adequacy of your Programme with all of your AML/CTF obligations, identify any problem areas, and help you find solutions to rectify deficiencies and ensure compliance.

‍