DIA Formal Warning: Hills Real Estate Limited
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.” ...