First AML Criminal Case

R v QF, FC and JFL [2019] NZHC 3058

Lan’s Enterprise Limited Training Program

2024 Q1 Training

Training Objectives

What you’ll learn today:

  • Understand New Zealand’s first AML/CFT Act criminal prosecution
  • Recognize corporate and personal liability under derivative responsibility
  • Identify the four representative charges and their legal implications
  • Learn the objective test for suspicious transactions
  • Understand the critical importance of credibility in AML compliance

Case Overview

R v QF, FC and JFL [2019] NZHC 3058

22 November 2019

This is NOT a money-laundering prosecution. Rather, this case tests whether the Company complied with its obligations under the AML/CFT Act.

First criminal prosecution under New Zealand’s AML/CFT regime.

Critical Context

The Nature of This Case

  • Tests compliance with AML/CFT obligations
  • Not about money laundering itself
  • Focuses on reporting entity’s procedural failures
  • Establishes precedent for future prosecutions

The Parties Involved

Company (Reporting Entity)

  • Money remittance and currency exchange business
  • Primary obligations under AML/CFT Act
  • Liability is derivative (relies on director’s knowledge and actions)

The Parties Involved

Director

  • Company director
  • Faces same charges as Company
  • Liability arises by knowingly aiding or procuring Company’s failures

The Parties Involved

Mother (Employee)

  • Experienced in money remittance and currency exchange
  • Acting as employee and in other capacities
  • Faces same charges plus additional structuring charge

Derivative Liability Principle

Critical Understanding

By this logic, the dealers, the compliance, the management and the director could all be liable should the Company be found to be failing its obligations under the AML/CFT Act.

Personal liability follows corporate liability.

The Four Representative Charges

Charge 1: Structuring Transaction

Section 101 - Mother only

Structuring a transaction to avoid the application of AML/CFT requirements

The Four Representative Charges

Charge 2: Failing to Conduct CDD

Section 91 - All defendants

Failing to conduct customer due diligence as required under the Act

The Four Representative Charges

Charge 3: Failing to Report SAR

Section 92 - All defendants

Failing to report a suspicious transaction to the Commissioner

The Four Representative Charges

Charge 4: Failing to Keep Records

Section 95 - All defendants

Failing to keep or retain adequate records relating to a suspicious transaction

Transaction Volume Context

By The Numbers

  • 311 transactions in the relevant period
  • $53 million combined value
  • Allegations do not relate to the whole business
  • Court confirms most Company systems were compliant

Critical Principle

“Half Measures Availed Us Nothing”

If a job is worth doing, it’s worth doing right.

Partial compliance is insufficient. One compliance failure can result in criminal prosecution despite otherwise compliant systems.

AML/CFT Act Structure

Part 1: Preliminary Provisions

Definitions, scope, application of the Act

AML/CFT Act Structure

Part 2: AML/CFT Requirements and Compliance

Subpart 1: Customer Due Diligence obligations (simplified, standard, enhanced)

Subpart 2: Suspicious transaction reporting duties

Subpart 3: Record-keeping requirements for transactions

Subpart 4: Compliance programmes and compliance officers

AML/CFT Act Structure

Part 3: Enforcement

Civil and criminal enforcement regimes for non-compliance

Section 78: Defines civil liability acts

Section 91: Civil liability act done knowingly or recklessly = criminal offence

AML/CFT Act Structure

Part 4: Institutional Arrangements

Supervisory bodies, miscellaneous provisions

Civil Liability Acts

Section 78 Defines Non-Compliance

  • Failing to conduct customer due diligence
  • Failing to adequately monitor accounts and transactions
  • Entering/continuing business relationship without satisfactory identity evidence
  • Entering/continuing correspondent banking relationship with shell bank
  • Failing to keep records
  • Failing to establish, implement, or maintain AML/CFT programme
  • Failing to ensure branches and subsidiaries comply

The DIA Investigation

How It Started

DIA resurrected its interest in the Company after contact by Police investigating Mr A (high net worth client - $36.2 million in transactions).

The DIA Investigation

On-Site Inspection

23 June 2016: DIA notified Company of on-site inspection

24 August 2016: Inspection conducted with specific focus on Mr A’s transactions

DIA required documents including employee lists, training logs, and bank account lists

The DIA Investigation

Critical Findings

  • Company never reported any transactions relating to Mr A
  • No customer record for Mr A found on Company’s system
  • Company claimed Mr A was the mother’s personal client, not Company’s client
  • DIA dissatisfied with explanations provided

The DIA Investigation

Section 132 Notice

7 September 2016: DIA served notice requiring production of documents

Request included: All records (standard and enhanced CDD) relating to customers, enabling transaction reconstruction, including originator and beneficiary information

Charge One: Structuring

Section 101 of the AML/CFT Act

“A person commits an offence if the person structures a transaction (other than a transaction that involves the cross-border transportation of cash) to avoid the application of any AML/CFT requirements.”

Charge One: Structuring

Application and Verdict

Applies when dealers:

  • Knowingly avoid AML/CFT requirements
  • Show wilful blindness
  • Help structure transactions to avoid CDD

Verdict: Mother found GUILTY on Charge 1

Charge Two: Failing to Conduct CDD

Section 11 of the AML/CFT Act

Reporting entity must conduct CDD on:

  • Customer
  • Any beneficial owner of customer
  • Any person acting on behalf of customer

Charge Two: Failing to Conduct CDD

Customer Presumption

Section 11(2): A customer who is an individual shall be treated as the beneficial owner UNLESS the reporting entity has reasonable grounds to suspect that customer is not the beneficial owner.

Charge Two: Failing to Conduct CDD

Recklessness Standard

Recklessness established by:

  • Awareness of the risk
  • Having regard to that risk, acting unreasonably

Unreasonable action: One that a reasonable and prudent person doing their best to comply with the law would not take.

Charge Two: Failing to Conduct CDD

Verdict

Company failed to conduct CDD on Mr A as required.

All defendants found GUILTY on Charge 2:

  • Company
  • Director
  • Mother

Charges Three and Four

Section 92: Failing to Report SAR

A reporting entity commits an offence if:

  • Transaction conducted or sought to be conducted
  • Reporting entity has reasonable grounds to suspect transaction is relevant to money laundering investigation, drug enforcement, terrorism, proceeds of crime, or serious offence
  • Reporting entity fails to report within 3 working days of forming that suspicion

Charges Three and Four

Section 95: Failing to Keep Records

“A reporting entity commits an offence if the reporting entity fails to keep or retain adequate records relating to a suspicious transaction.”

Charges Three and Four

Reasonable Grounds to Suspect

Judge’s finding:

“The most telling indicia is the volume and frequency of remittances over an extended period without any stated or recorded commercial objective other than the inherent purpose of removing money from China.”

Volume and frequency at the centre of this matter.

Charges Three and Four

Verdict

Company found GUILTY:

  • Failing to file SAR for any transactions relating to Mr A (19 May 2015 - 10 May 2016)
  • Failing to retain adequate records relating to those transactions

Director and Mother found GUILTY:

  • Chat messages and evidence conclude both considered Mr A’s transactions suspicious
  • Should have been reported under AML regime
  • Denials rejected

The Objective Test for Suspicion

Department of Internal Affairs v Ping An Finance

First determination of pecuniary penalties under AML/CFT Act

[2017] NZHC 2363 - Money remitter case

Established the objective test for suspicious transactions

The Objective Test for Suspicion

“The test of whether a transaction is ‘suspicious’ is objective, and not subjective.”

Reporting entities must report any transaction that is “objectively suspicious.”

The Objective Test for Suspicion

What This Means

“Where an objective observer would conclude that reasonable grounds for suspicion were known to the reporting entity, it is no defence that the reporting entity did not actually consider the transaction to be suspicious.”

Your personal opinion does not matter. The standard is what a reasonable observer would conclude.

The Objective Test for Suspicion

When Obligation Arises

“The obligation to report must be held to arise when the reporting entity either becomes aware of the facts constituting the reasonable grounds for suspicion, or by reasonable diligence would have become aware of them.”

Wilful blindness is not a defence.

The Importance of Credibility

Crown’s Position

The Crown suggested that the director’s explanations of the transactions:

  • Lacked credibility
  • Were implausible
  • Were fabricated with hindsight

Judge determined that the defendants did lie.

The Importance of Credibility

Consequences of Lying

“The defendants’ fate were decided when they lie.”

  • A liar will not be believed, even when speaking the truth
  • The biggest consequence of lying is losing trust
  • Credibility is everything in AML compliance

Critical Lessons Learned

Lesson 1: Partial Compliance is Insufficient

“Half measures availed us nothing.” Even with mostly compliant systems, one significant failure can result in criminal prosecution.

Critical Lessons Learned

Lesson 2: Personal Liability is Real

Directors, compliance officers, managers, and dealers can all be held personally liable through derivative responsibility.

Critical Lessons Learned

Lesson 3: The Test is Objective

Your subjective belief about whether a transaction is suspicious is irrelevant. What matters is what a reasonable observer would conclude.

Critical Lessons Learned

Lesson 4: Volume and Frequency Matter

Repeated transactions over extended periods without clear commercial purpose are highly suspicious, especially when involving funds leaving the country.

Critical Lessons Learned

Lesson 5: Credibility is Everything

Fabricating explanations or lying to investigators destroys credibility and determines your fate. Honesty and transparency are paramount.

Critical Lessons Learned

Lesson 6: “No Exception” Cannot Exist

Treating any client as exempt from AML/CFT obligations (claiming they’re “personal” clients, not company clients) is unlawful and will be prosecuted.

Critical Lessons Learned

Lesson 7: Document Everything

Failing to maintain adequate records compounds other violations. Documentation is your defence and legal obligation.

Key Takeaways

Remember These Points

  1. This was New Zealand’s first AML/CFT Act criminal prosecution

    • Establishes precedent for corporate and personal liability
  2. Derivative liability extends to all staff levels

    • Dealers, compliance, management, and directors can all be prosecuted
  3. The objective test for suspicion applies

    • Your personal opinion is irrelevant; reasonable observer standard controls

Key Takeaways

Remember These Points (continued)

  1. Volume and frequency are telling indicia

    • Repeated transactions without clear commercial purpose trigger reporting obligations
  2. Credibility determines outcomes

    • Lying or fabricating explanations will destroy your case
  3. Partial compliance is not compliance

    • “Half measures availed us nothing” - complete compliance required

Staying Vigilant

Our Commitment

As a financial institution committed to upholding the highest standards of integrity and compliance, we must remain vigilant and steadfast in adherence to AML/CFT obligations.

Stay focused on the bigger picture: regulatory compliance and ethical conduct over immediate profits.

Contact & Resources

For Further Information

  • AML Compliance Team: aml@gmfinance.co.nz
  • Emergency Hotline: +64 09-309-8808
  • Training Program: Lan’s Enterprise Limited

Questions?

Thank You

Stay Vigilant, Stay Compliant