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Published: 28 July 2025
Authors: Neil Russ, Serge Sablyak
Pages: 79

Content outline

  • Introduction
  • What is money laundering and terrorism financing?
  • The challenge of money laundering
  • The money laundering process
  • Global AML and CFT initiatives
  • The historical approach to money laundering in New Zealand
  • Global AML standards arrive in New Zealand
  • Territorial scope
  • Ordinary course of business
  • AML/CFT Act extended to lawyers, accountants, real estate agents and high-value dealers
  • Exclusions and exemptions
  • Phase 2 staged implementation
  • Law firm compliance in more detail
  • Compliance Officer
  • Risk assessment
  • Compliance programme
  • Customer due diligence
  • Types of CDD
  • Identity verification code of practice
  • Source of wealth or funds
  • CDD after establishing a business relationship
  • CDD required only for captured activities
  • Ongoing CDD monitoring
  • Look through to beneficial owners
  • Register of beneficial ownership
  • Suspicious activity reports
  • Record keeping
  • Audit
  • Annual return
  • Breaches
  • Designated business groups
  • Conclusion
 
RUSS Neil-225  
Neil Russ
Russ + Associates Auckland		 Serge Sablyak 
Department of Internal Affairs
Wellington

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