Guidance Note: Updating AML/CFT Risk Assessment and Programme
This guidance note is prepared to help reporting entities (REs) to update their AML/CFT risk assessment, and programme in the light of:
- Updated guidelines published, in May 2018, by the AML/CFT supervisors;
- The most recent National Risk Assessment and Quarterly Typology Reports published by the Financial Intelligence Unit of the NZ Police, and the Sector Risk Assessment published by the FMA in July 2017;
- The issues regularly uncovered by Strategi when undertaking AML/CFT audits for Phase 1 entities, and
- The AML/CFT ministerial exemption, which came into effect from 30 June 2018, for all financial advisers who act as an intermediary in selling certain retirement scheme products of product providers (i.e. managers of the relevant retirement schemes).
The guidance note starts with a description of the common issues with risk assessments and programmes, and provides recommendations for updating these two documents to meet the minimum requirements of the Act, and the expectations of the AML/CFT supervisors. The guidance note also describes how Strategi Institute Limited (a sister entity of Strategi Limited) can help REs comply with the Act.