Money Remitter

DIA Formal Warning NZForex Limited — 3,182 Unreported PTRs 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 to NZForex Limited on 18 March 2025 3,182 prescribed transactions were not reported to the FIU Reporting gap spanned 1 November 2017 → 28 February 2024 — over six years All unreported transactions were non-NZD denominated No allegation of money laundering — this was a system / reporting-control failure Who is NZForex? Online foreign-exchange and international payments business Reporting entity under the AML/CFT Act 2009 Required to file: International Funds Transfers (IFTs) ≥ NZ$1,000 cross-border Large Cash Transactions (LCTs) ≥ NZ$10,000 in cash Collectively known as Prescribed Transaction Reports (PTRs) What Went Wrong The system issue A defect in NZForex’s PTR processing pipeline Affected transactions not denominated in New Zealand Dollars Non-NZD volumes silently bypassed the reporting workflow The defect persisted for 6 years and 4 months undetected by internal monitoring What was missed 3,182 individual prescribed transactions Each was a separately reportable obligation under section 48A How It Was Discovered NZForex itself identified the issue The defect surfaced through internal system review — not a DIA finding NZForex voluntarily disclosed the non-compliance to DIA Backfill: all 3,182 transactions were submitted to the FIU An independent audit was commissioned voluntarily The Regulator’s Position “DIA acknowledges that NZForex has voluntarily disclosed the non-compliance, and we commend NZForex for disclosing the non-compliance, admitting fault and taking steps to resolve the system issue.” ...

Record Sentence Ye Hua and NZ’s Largest ML Conviction Lan’s Enterprise Limited Training Program Presented by: Angela Ji Contact: aml@gmfinance.co.nz Emergency Hotline: +64 09-309-8808 Overview 7 years 6 months — the longest money laundering sentence in NZ history At least NZ$18 million laundered for an international drug syndicate Sentenced 16 November 2023 in Auckland District Court This deck focuses on sentencing reasoning and operational red flags — the offending pattern itself is covered in the Q3 2022 Ye Hua case study Who Was Convicted Ye “Cathay” Hua, 58 years old Churchgoing matriarch of a prosperous Auckland family Money exchange business funded a St Heliers mansion Director of Lidong Foreign Exchange — money shop at 1 Kent St, Newmarket In Valent’s encrypted messages: “Newmarket money lady” / “money shop” Found guilty of 15 of 19 charges (jury verdict, July 2023, three-week trial) Maximum penalty per charge: 7 years The Underlying Criminal Enterprise Principal: Xavier Valent Sentenced to life imprisonment for leading the syndicate Imported 100+ kilograms of methamphetamine into NZ between 2016 and 2020 Hua was the syndicate’s primary money-laundering channel for cash proceeds How the cash moved Cash deposits at Lidong Foreign Exchange International wires from the same money-changer Bitcoin conversions Direct transactions with low-level dealers and Valent’s lieutenants The Numbers Argued at Trial Party Dollar amount Crown $26 million Judge’s finding At least $18 million Defence $6-10 million “By value, Ms Hua’s offending is many magnitudes more serious than any other case which has been before a court in this country.” ...