First AML Criminal Case: R v QF, FC and JFL

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 ...

January 14, 2024 · Angela Ji

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.” ...

October 15, 2023 · Angela Ji

KYC Issues and Challenges: The Barclays Private Banking Case

KYC Issues and Challenges The Barclays Private Banking Case Study Lan’s Enterprise Limited Training Program Training Objectives What you’ll learn today: Understand the importance of Enhanced Due Diligence for high-risk customers Recognize critical failures in KYC processes with PEPs Identify the consequences of prioritizing profit over compliance Apply lessons learned to prevent similar violations Strengthen ongoing monitoring and record-keeping practices Case Overview The Barclays Bank Incident Year: 2011-2012 transaction, fined in 2015 Regulator: UK Financial Conduct Authority (FCA) Transaction Value: £1.88 billion Customer Type: Ultra-high net-worth PEPs Fine Amount: £72 million (highest AML fine by FCA at the time) The Background High-Risk Private Banking Transaction What happened: ...

July 16, 2023 · Angela Ji

The Billion Dollar Scam: Global Investment Fraud Through Premier League Sponsorship

The Billion Dollar Scam How Companies Used Premier League Sponsorship to Target Unsuspecting Football Fans Lan’s Enterprise Limited Training Program Training Objectives What you’ll learn today: Understand how global fraud networks recruit and target retail investors through sports marketing Identify red flags and warning signs of high-return investment scams Recognize the role of sports sponsorships and celebrity endorsements in creating false legitimacy Implement enhanced controls and due-diligence processes to detect and prevent similar scams Apply lessons learned to strengthen our AML/CFT practices and investor protection About This Case Study BBC Eye Investigation Documentary: “The Billion Dollar Scam” First Broadcast: April 12, 2023 (BBC World Service) Lead Reporter: Simona Weinglass Duration: 27 minutes Scope: Global criminal network investigation spanning multiple continents Note: Original YouTube video may no longer be available ...

July 1, 2023 · Angela Ji

Customer Onboarding Scenarios - Q2 2023

Customer Onboarding Scenarios Q2 2023 Training Lan’s Enterprise Limited Training Program Training Objectives What you’ll learn today: Identify required persons and entities in complex corporate structures Determine appropriate documentation for different customer types Recognize beneficial ownership requirements and thresholds Apply enhanced due diligence for high-risk scenarios Navigate PEP identification and risk management How This Training Works Interactive Scenarios Read each scenario carefully Think about your approach before revealing the answer Consider who, what, and which forms you need Compare with best practice solutions Scenario 1 Amazing Dude Limited Scenario 1: The Facts AMAZING DUDE LIMITED ...

June 30, 2023 · Angela Ji

DIA AML/CFT Videos: Keeping New Zealand in Business for Good

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 ...

April 16, 2023 · Angela Ji

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

Anti-Money Laundering Training: Case Study of Ye Hua

Anti-Money Laundering Training Case Study of Ye Hua Lan’s Enterprise Limited Training Program Understanding Money Laundering “Money laundering is not just a crime - it’s a gateway to enabling other serious criminal activities.” Definition: The process of making illegally-obtained money appear legal Global Impact: Estimated $2 trillion laundered annually Our Responsibility: Prevention, detection, and reporting Why This Training Matters Regulatory Requirements AML/CFT Act compliance Regulatory reporting obligations Personal liability risks Business Protection Reputation safeguarding Financial security Criminal liability prevention The Ye Hua Case: A Warning Tale Key Facts Laundered: $18 million Method: Money exchange business Sentence: 7½ years imprisonment Connection: Drug trafficking syndicate Red Flags Missed Unusual Transaction Patterns ...

August 18, 2022 · Angela Ji

Investigation Houston: The ING Bank Compliance Failure

Investigation Houston The ING Bank AML Compliance Failure Lan’s Enterprise Limited Training Program Training Objectives What you’ll learn today: Understand how a major international bank failed its AML obligations Identify systemic compliance failures and their root causes Recognize the consequences of prioritizing business over compliance Learn key red flags that were missed for years Apply lessons to prevent similar failures in your organization Case Overview ING Bank N.V. - The Facts Institution: ING Bank Nederland (ING NL) Period: 2010-2016 Investigation: “Operation Houston” by Dutch FIOD Settlement: €775 million (September 2018) Status: Only Dutch bank on Global Systemic Banks list What Is a Systemic Bank? Critical Infrastructure 9 million account holders in Netherlands 340 million payment transactions per month Essential to financial system functioning Higher responsibility for system integrity Trusted reputation in national/international trade With great power comes great responsibility ...

June 30, 2022 · Angela Ji

Know Your Customers: The Complete KYC Cycle

🧩 Know Your Customers Get the Picture: The Complete KYC Cycle Q1 2022 Quarterly Training Lan’s Enterprise Limited Training Program Presented by: Angela Ji Do You Really Know Your Customers? “You think you know me, but you don’t know me…” The Reality: Knowing your customers is not a one-time event—it’s an ongoing journey of trust, vigilance, and verification. Training Objectives What you’ll learn today Understand the 6-step KYC cycle and why it never ends Identify when and how to perform Customer Due Diligence (CDD) Recognize situations requiring Enhanced Due Diligence (ECDD) Implement effective ongoing monitoring and transaction review Maintain proper records for regulatory compliance 🌍 The Risk-Based Approach One Size Does Not Fit All KYC depth depends on customer risk level Apply proportionate measures for low, medium, and high-risk profiles Reassess risk whenever new information arises Document rationale for every risk rating decision KYC: It Never Ends The 6-Step Continuous Cycle 👤 Identification – Verify who they are 🔍 CDD – Customer Due Diligence ⚠️ ECDD – Enhanced Due Diligence 🔄 Ongoing CDD – Keep information current 📊 Transaction Monitoring – Watch activity patterns 🧾 Account Review – Regular comprehensive assessment Step 1: Identification Making Sure Customers Are Who They Claim to Be Two Key Timing Requirements: Verify identity before starting the business relationship Verify identity periodically over time Core Principle: Ensure customers are genuinely who they claim to be throughout the entire relationship. ...

January 1, 2022 · Angela Ji