DIA Formal Warning: NZForex Limited — 3,182 Unreported PTRs
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.” ...