CDD

Onboarding Customers with Complex Ownership Structures Q3 2025 Quarterly Training Lan’s Enterprise Limited Training Program Training Objectives What you’ll learn today: Understand obligations for penetrating complex ownership structures Identify beneficial owners through multi-layer entities Apply Enhanced CDD in high-risk scenarios Navigate trust structures and nominee arrangements Establish effective control in layered ownership Why This Matters AML/CFT Obligations Reporting entities must go beyond surface-level ownership and penetrate through complex structures to identify ultimate beneficial owners (UBOs) and effective controllers. ...

Customer Risk Rating Guideline Q1 2025 - Risk Assessment Framework Lan’s Enterprise Limited Training Program Training Objectives What you’ll learn today: Understand the risk-based approach (RBA) to AML/CFT compliance Identify key risk factors in customer assessment Apply the customer risk rating framework Recognize high, medium, and low risk indicators Implement ongoing monitoring and risk reassessment The Risk-Based Approach Two Pillars of AML/CFT Compliance Holistic Risk Assessment Business-wide risk evaluation Product, service, and channel analysis Targeted Risk Assessment ...

AML/CFT Webinar Customer Due Diligence — 2024 Refresh Lan’s Enterprise Limited Training Program Presented by: Angela Ji Contact: aml@gmfinance.co.nz Emergency Hotline: +64 09-309-8808 Overview 10 May 2024 — DIA, FMA and RBNZ jointly published updated CDD guidance Tied to AML/CFT Amendment Regulations 2023 in force from 1 June 2024 Five new guideline documents replacing/supplementing prior CDD guidance This session walks through what changed and what we must adopt at LEL Why the Refresh? 2021 Statutory Review of the AML/CFT Act identified gaps in CDD practice 2023 amending regulations clarified beneficial-ownership obligations Supervisors aligned on a single, risk-based, principles-based interpretation Real-world enforcement (Hills, SkyCity, Jiaxin) reinforced the need for clearer guidance The Five New Documents # Document Focus 1 Beneficial Ownership Guideline Identifying and verifying the natural-person owner behind every customer 2 CDD: Companies Standard and enhanced CDD on incorporated customers 3 CDD: Trusts Settlor / trustee / beneficiary / class verification 4 CDD: Limited Partnerships General partner ID + LP register checks 5 Enhanced CDD When ECDD is triggered, what extra steps are required What Changed — Beneficial Ownership 25% threshold confirmed for beneficial ownership of companies — but also any person with effective control regardless of shareholding Multi-layer corporate structures: must drill through every layer to natural persons Where no natural person can be identified, senior managing official must be CDD’d Document the reasoning — the supervisor wants to see how you concluded What Changed — Trusts & LPs Trusts CDD on every named beneficiary, settlor, trustee, and protector Where beneficiaries are a class, the class must be described and CDD applied to known members Discretionary trusts get extra scrutiny Limited Partnerships General partner is treated as the responsible party LP register must be checked against customer-provided info Foreign LPs trigger ECDD by default What Changed — Enhanced CDD ECDD triggers (refreshed) Trusts and vehicles dealing with assets Companies with nominee shareholders or directors Politically Exposed Persons (PEPs) Customers from high-risk jurisdictions Wire transfers above prescribed thresholds Anything else the entity’s risk assessment flags ECDD requirements Source of funds and source of wealth Senior management approval Enhanced ongoing monitoring frequency The Risk-Based Approach “Reporting entities must tailor their AML/CFT programme to their specific risk profile.” ...

Responsibilities Under Money Laundering Supervision Q2 2024 - Your Role as a Reporting Entity Member Lan’s Enterprise Limited Training Program Training Objectives What you’ll learn today: Understand your responsibilities as a reporting entity member Identify the four key areas of AML/CFT compliance Apply customer due diligence requirements correctly Recognize when enhanced due diligence is required Implement effective internal controls and monitoring Your AML Responsibilities Every Team Member Matters As a reporting entity under the AML Act, every member has responsibility under money laundering supervision. ...

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 ...

DIA Formal Warning Hills Real Estate Limited Lan’s Enterprise Limited Training Program Presented by: Angela Ji Contact: aml@gmfinance.co.nz Emergency Hotline: +64 09-309-8808 Overview DIA issued a formal warning under s80 AML/CFT Act 2009 Warning date: 8 May 2023 — publicly announced 6 July 2023 Second formal warning to a real estate agent within two months Signals DIA’s escalating enforcement posture against non-bank reporting entities Who is Hills Real Estate? South Auckland real estate agency A reporting entity under the AML/CFT Act since 1 January 2019 (real-estate sector phase-in) Required to maintain a full AML/CFT compliance programme, conduct CDD, monitor activity, and keep records — the same obligations that apply to financial institutions What DIA Found Four areas of non-compliance AML/CFT Programme — failed to establish, implement and maintain an adequate programme Ongoing CDD — neglected ongoing customer due diligence obligations Monitoring & review — insufficient transaction monitoring to detect grounds for SAR reporting Record keeping — failed to maintain records as required by the Act The Regulator’s Position “Real estate agencies should take note of the two recent warnings and expect stronger action for serious breaches. DIA uses escalating enforcement tools — from educational guidance through to prosecution.” ...

KYC Issues and Challenges The Barclays Private Banking Case Study Lan’s Enterprise Limited Training Program Training Objectives What you’ll learn today: Understand the importance of Enhanced Due Diligence for high-risk customers Recognize critical failures in KYC processes with PEPs Identify the consequences of prioritizing profit over compliance Apply lessons learned to prevent similar violations Strengthen ongoing monitoring and record-keeping practices Case Overview The Barclays Bank Incident Year: 2011-2012 transaction, fined in 2015 Regulator: UK Financial Conduct Authority (FCA) Transaction Value: £1.88 billion Customer Type: Ultra-high net-worth PEPs Fine Amount: £72 million (highest AML fine by FCA at the time) The Background High-Risk Private Banking Transaction What happened: ...

Customer Onboarding Scenarios Q2 2023 Training Lan’s Enterprise Limited Training Program Training Objectives What you’ll learn today: Identify required persons and entities in complex corporate structures Determine appropriate documentation for different customer types Recognize beneficial ownership requirements and thresholds Apply enhanced due diligence for high-risk scenarios Navigate PEP identification and risk management How This Training Works Interactive Scenarios Read each scenario carefully Think about your approach before revealing the answer Consider who, what, and which forms you need Compare with best practice solutions Scenario 1 Amazing Dude Limited Scenario 1: The Facts AMAZING DUDE LIMITED ...

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 ...

🧩 Know Your Customers Get the Picture: The Complete KYC Cycle Q1 2022 Quarterly Training Lan’s Enterprise Limited Training Program Presented by: Angela Ji Do You Really Know Your Customers? “You think you know me, but you don’t know me…” The Reality: Knowing your customers is not a one-time event—it’s an ongoing journey of trust, vigilance, and verification. Training Objectives What you’ll learn today Understand the 6-step KYC cycle and why it never ends Identify when and how to perform Customer Due Diligence (CDD) Recognize situations requiring Enhanced Due Diligence (ECDD) Implement effective ongoing monitoring and transaction review Maintain proper records for regulatory compliance 🌍 The Risk-Based Approach One Size Does Not Fit All KYC depth depends on customer risk level Apply proportionate measures for low, medium, and high-risk profiles Reassess risk whenever new information arises Document rationale for every risk rating decision KYC: It Never Ends The 6-Step Continuous Cycle 👤 Identification – Verify who they are 🔍 CDD – Customer Due Diligence ⚠️ ECDD – Enhanced Due Diligence 🔄 Ongoing CDD – Keep information current 📊 Transaction Monitoring – Watch activity patterns 🧾 Account Review – Regular comprehensive assessment Step 1: Identification Making Sure Customers Are Who They Claim to Be Two Key Timing Requirements: Verify identity before starting the business relationship Verify identity periodically over time Core Principle: Ensure customers are genuinely who they claim to be throughout the entire relationship. ...