Compliance

AML Case Study The Jiaxin Finance Investigation 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 Jiaxin Finance DIA investigation and its context Identify the compliance failures that triggered regulatory action Recognise the enforcement pathway DIA follows for money remitters Apply the lessons learned to LEL’s own compliance operations Reinforce the importance of proactive compliance over reactive remediation Overview DIA conducted a compliance investigation into Jiaxin Finance, a money remitter Investigation revealed systemic AML/CFT compliance failures Case is part of DIA’s escalating enforcement posture against non-bank reporting entities Money remitters remain a high-priority supervisory target for DIA Follows a pattern of enforcement actions against remitters: Ping An Finance, Lidong Foreign Exchange, NZForex DIA Enforcement Context Money remitters under the spotlight The AML/CFT Act 2009 applies equally to all reporting entities — banks and non-banks alike DIA has explicitly signalled that money remitters face heightened scrutiny Remittance sector is identified as high-risk for money laundering due to: High-volume, cross-border cash flows Customer base often involving migrant remittances Potential for structuring and layering Variable compliance maturity across the sector DIA Enforcement Pathway Escalating regulatory tools Educational guidance — informal engagement Directions — formal requirement to act Formal warning — public record under s80 Civil penalty — pecuniary penalty order Criminal prosecution — for knowing or reckless breaches “Money remitters should expect stronger action for serious breaches. DIA uses escalating enforcement tools — from educational guidance through to prosecution.” ...

AML Compliance Case Study SkyCity Casino $4.16M Fine Lan’s Enterprise Limited Training Program Presented by: Angela Ji Contact: aml@gmfinance.co.nz Emergency Hotline: +64 09-309-8808 Overview Major AML/CFT breaches spanning 5 years (2018-2023) Systemic failures in compliance program $4.16M penalty imposed by regulators Focus on international business customers No direct evidence of money laundering found, but serious control gaps identified Key Compliance Failures Risk Assessment & Program Management Inadequate AML/CFT compliance programme Failures in risk assessment processes Systemic non-compliance with core obligations Customer Due Diligence Poor monitoring of accounts and transactions Insufficient enhanced due diligence Failures to terminate high-risk relationships Timeline Violations occurred Feb 2018 - March 2023 DIA review conducted Sept 2022 - Dec 2023 Penalty finalized January 2025 Regulatory Context “Casinos can be an attractive way for criminals to launder proceeds of crime. We cannot take the risk that criminals might choose New Zealand casinos as a way of cleaning their dirty money. Casinos must have robust processes in place to protect them from misuse.” ...

2024 Q4 AML Knowledge Quiz Testing Your Anti-Money Laundering Expertise Lan’s Enterprise Limited Training Program Welcome to the Quiz Test your understanding of: Money laundering offences and stages Suspicious Activity Reporting (SAR) Customer Due Diligence (CDD) requirements Politically Exposed Persons (PEP) Compliance obligations AML terminology and concepts Instructions How this quiz works: 10 questions covering key AML topics Read each question carefully Think about your answer before advancing Correct answers and explanations will be revealed Take your time and reflect on each question Question 1 Money Laundering Offences Which of the following acts is NOT considered to be a money laundering offence? ...

2024 Q3 AML Regulatory Inspection Focus Update Insights for Chinese Money Remitters Lan’s Enterprise Limited Training Program Training Objectives What You’ll Learn Today Ensure alignment between business practice and AML programme documentation Understand Chinese remittance characteristics and address regulatory misunderstandings Implement enhanced record keeping with proper time stamps and file notes Apply a holistic approach to Enhanced Customer Due Diligence (ECDD) Prepare effectively for upcoming regulatory inspections Overview Regulatory Inspection Context Several business partners are currently undergoing regulatory onsite visits. This training provides critical insights from recent inspections to help all BPs prepare effectively. ...

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 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 ...

FIU/ACAMS Conference 2022 Case Study Review Lan’s Enterprise Limited Training Program Presented by: Angela Ji Contact: aml@gmfinance.co.nz Emergency Hotline: +64 09-309-8808 Training Objectives What You’ll Learn Today Understand the role of the NZ Financial Intelligence Unit (FIU) and its priorities Review key case studies presented at the FIU/ACAMS Conference 2022 Identify AML/CFT compliance lessons directly relevant to money remitters Learn about evolving enforcement trends and regulatory expectations Apply conference insights to strengthen our day-to-day compliance practices Conference Background FIU/ACAMS Conference 2022 Annual event hosted jointly by the NZ Police Financial Intelligence Unit and ACAMS Brought together regulators, law enforcement, and reporting entities Focused on emerging ML/TF typologies and real-world enforcement case studies Key themes: remittance sector risks, proceeds of crime, and CDD failures Provided critical insights into how FIU analyses suspicious transaction reports (STRs) The NZ Financial Intelligence Unit Who They Are Part of NZ Police, based in Wellington Receives, analyses, and disseminates Suspicious Transaction Reports (STRs) Produced over 5,000 financial intelligence disclosures in the 2021/22 year Works with the three AML/CFT supervisors: DIA, RBNZ, and FMA Key partner in identifying and disrupting money laundering networks The NZ Financial Intelligence Unit Their Role in Our Business Every SAR/STR we file goes to the FIU FIU connects our reports with intelligence from other sources Their analysis can trigger criminal investigations They assess whether remittance businesses are meeting their reporting obligations Under-reporting is a red flag — FIU knows the expected volume for our sector Key Theme 1: Remittance Sector Under Spotlight Why Money Remitters Were a Focus Remittance businesses identified as high-risk for money laundering FIU reported that the DNFBP and remittance sector had lower STR filing rates than banks Conference highlighted patterns of structuring, smurfing, and third-party transfers through remitters Regulators expect remitters to have robust transaction monitoring and proactive SAR filing Key Theme 1: Remittance Sector Under Spotlight What This Means for LEL We are in a high-priority sector for regulatory attention Our SAR filing patterns are compared against sector benchmarks Failure to detect and report suspicious activity is treated as a compliance failure Transaction monitoring must be documented and reviewable “Remitters are a gateway for cross-border value transfer. That makes you both a risk and a line of defence.” — FIU Conference Presenter ...

AML/CFT Act vs Privacy Act Balancing Competing Legal Obligations Q4 2021 Quarterly Training Lan’s Enterprise Limited Training Program Training Objectives What you’ll learn today Understand the hierarchy of laws and how legislation ranks in authority Recognize how the AML/CFT Act overrides Privacy Act in specific circumstances Identify privacy principles that still apply during AML/CFT compliance Learn best practices for client communication about information requirements Understand privacy breach protocols and internal processes The Legal Hierarchy Laws Function in Order of Authority From highest to lowest authority: ...