DIA AML/CFT Videos

Keeping New Zealand in Business for Good

Lan’s Enterprise Limited Training Program

Presented by: Angela Ji Contact: aml@gmfinance.co.nz Emergency Hotline: +64 09-309-8808

Training Objectives

  • Understand the DIA’s role as an AML/CFT supervisor in New Zealand
  • Review the key themes from the DIA’s educational video series
  • Identify compliance obligations specific to money remitters
  • Learn practical steps to strengthen our AML/CFT programme
  • Understand why compliance matters for keeping NZ in business for good

DIA’s Role and AML/CFT Mission

  • The Department of Internal Affairs (DIA) is one of three AML/CFT supervisors in New Zealand
  • DIA supervises non-bank financial institutions — including money remitters like LEL
  • Other supervisors: Reserve Bank of New Zealand (banks) and Financial Markets Authority (securities)
  • DIA’s mission: protect New Zealand’s financial system integrity and international reputation

“Keeping NZ in Business for Good”

“Keeping New Zealand in business for good” — DIA’s AML/CFT awareness message

  • “In business” — compliance enables legitimate commerce to thrive
  • “For good” — ethical, sustainable business practices protect our reputation
  • Money laundering undermines trust, fairness, and economic stability
  • New Zealand’s low-corruption reputation is a competitive advantage we must protect

The DIA Educational Video Series

  • DIA produces educational videos and resources to help reporting entities understand their obligations
  • Videos cover the full compliance lifecycle — from risk assessment to record-keeping
  • Targeted at all reporting entity types, with specific guidance for non-bank financial institutions
  • Resources available on the DIA website and through sector-specific guidance

Key Video Theme 1: Risk Assessment

  • Every reporting entity must conduct a risk assessment of its business
  • Must identify ML/TF risks specific to your services, customers, and jurisdictions
  • Money remitters face elevated risks due to:
    • High-volume cross-border transfers
    • Cash-intensive transactions
    • Exposure to high-risk jurisdictions
  • Risk assessment must be documented and reviewed regularly

Key Video Theme 2: AML/CFT Programme

  • Your AML/CFT programme must be tailored to your risk assessment
  • A generic, off-the-shelf programme is not sufficient
  • Programme must include:
    • CDD procedures
    • Ongoing monitoring processes
    • SAR reporting procedures
    • Record-keeping systems
    • Staff training requirements
  • DIA emphasises: a programme that exists only on paper is a breach

Key Video Theme 3: Customer Due Diligence (CDD)

  • Standard CDD — verify identity before establishing a business relationship
  • Must collect: full name, date of birth, address, identity document
  • For money remitters: beneficiary information is also critical
  • Enhanced CDD required for:
    • High-risk customers (PEPs, complex structures)
    • High-risk jurisdictions
    • Unusual transaction patterns
  • Ongoing CDD — not a one-time check, must be continuous

Key Video Theme 4: Ongoing Monitoring

  • Monitoring is an active obligation — not passive observation
  • Must have systems to:
    • Detect unusual transactions or behaviour
    • Review customer activity against their profile
    • Identify grounds for SAR reporting
  • DIA’s key message: monitoring must produce evidence of review
    • System logs alone are insufficient
    • Must show human review with dated documentation

Key Video Theme 5: Suspicious Activity Reporting

  • SARs must be filed when you have reasonable grounds to suspect ML/TF
  • Do not tip off the customer — tipping off is a criminal offence
  • SARs go to the Financial Intelligence Unit (FIU) at the NZ Police
  • Key points from DIA:
    • When in doubt, file a SAR
    • SAR filing does not mean you stop monitoring
    • Continue the business relationship unless directed otherwise
    • Document your decision-making process

Compliance Obligations for Money Remitters

Sector-Specific Requirements

  • Money remitters are classified as “financial institutions” under the AML/CFT Act
  • Must maintain a compliance programme approved by senior management
  • Domestic and international transfers both carry obligations
  • Correspondent banking relationships require enhanced scrutiny
  • Must verify both sender and beneficiary identity information

Compliance Obligations for Money Remitters

Record-Keeping Requirements

  • Must retain records for a minimum of 5 years after:
    • The end of the business relationship, or
    • The date of the transaction
  • Records must include:
    • CDD documentation (identity verification records)
    • Transaction records (amounts, dates, parties, jurisdictions)
    • SAR filings and internal investigation notes
    • Monitoring review records
  • Records are the regulator’s window into your compliance

Compliance Obligations for Money Remitters

Travel Rule and Wire Transfer Requirements

  • Originator information must accompany wire transfers
  • Required details: name, account number, address (or national ID, or customer ID, or date/place of birth)
  • Beneficiary information must also be captured
  • Intermediary institutions must pass on originator and beneficiary information
  • Purpose: create an audit trail for law enforcement

DIA’s Enforcement Approach

  • DIA uses a graduated enforcement model:
    1. Education and guidance
    2. Directions to comply
    3. Formal warnings (public)
    4. Civil penalty orders
    5. Prosecution
  • DIA has increasingly enforced against non-bank financial institutions
  • Money remitters are under active supervision
  • Public enforcement actions create reputational damage beyond the regulatory penalty

Practical Takeaways

What DIA Looks for During Supervision

  • Risk assessment — is it current, tailored, and documented?
  • Programme adequacy — does it address identified risks?
  • CDD implementation — are you actually doing what your programme says?
  • Monitoring evidence — can you show dated, reviewable artefacts?
  • SAR processes — are suspicious matters identified and reported?
  • Record-keeping — are records complete, accessible, and retained for 5+ years?
  • Training — are staff trained and is training documented?

Practical Takeaways

Common Gaps DIA Identifies

  • Risk assessments that are too generic or not updated
  • CDD processes that are not fully implemented
  • Ongoing CDD treated as a one-time onboarding exercise
  • Monitoring systems that generate alerts but no documented human review
  • Record-keeping gaps — missing documents, incomplete files, no retention policy
  • Training that is not documented or not refreshed

Practical Takeaways

Steps to Strengthen Compliance

  1. Review and update your risk assessment at least annually
  2. Map your CDD processes end-to-end — identify any gaps
  3. Document every monitoring review with date, reviewer, and findings
  4. Test your SAR procedures with scenario exercises
  5. Audit your records — can you produce complete files for any customer?
  6. Schedule regular training — and keep attendance records
  7. Conduct internal compliance reviews before DIA comes knocking

Why This Matters to LEL

Lan’s Enterprise Limited — Golden Mountain Finance

  • LEL is a money remitter supervised by DIA
  • We handle cross-border transfers — a high-risk category for ML/TF
  • Our compliance programme must be specific to our risk profile
  • Every transaction is an opportunity to detect suspicious activity
  • Every gap is a potential enforcement finding

Why This Matters to LEL

Real Consequences

  • Formal warnings are public — customers, partners, and competitors can see them
  • Civil penalties can reach hundreds of thousands of dollars
  • Criminal prosecution for serious or repeated breaches
  • Loss of licence — inability to operate as a remitter
  • Reputational damage — the hardest consequence to recover from
  • DIA’s message: voluntary self-detection is always cheaper than a regulatory finding

Key Takeaways

  1. DIA’s video resources are a guide to what the regulator expects — study them
  2. “Keeping NZ in business for good” means compliance protects our business and our country
  3. Risk assessment is the foundation — everything flows from it
  4. CDD is ongoing, not a one-time check at onboarding
  5. Monitoring must produce evidence — dated, reviewed, documented
  6. Record-keeping is your proof of compliance — gaps are treated as breaches
  7. Money remitters are under active DIA supervision — we must be audit-ready at all times

Questions?

Contact Information

Thank you for your attention

References

  • DIA — AML/CFT Guideline for Reporting Entities (Department of Internal Affairs)
  • DIA — Keeping New Zealand in Business for Good educational video series
  • AML/CFT Act 2009, Part 2 (obligations of reporting entities)
  • DIA — Sector guidance for money remitters and currency exchangers
  • FIU New Zealand — Suspicious Activity Reporting guidelines