FIU/ACAMS Conference 2022: Case Study Review

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 ...

January 9, 2023 · Angela Ji