AML/CT Compliance
War on Terror!

The US-led war on terror is now in the next stage of impacting on my business!!! First, it was FACTA.
The next sledgehammer to crack a walnut. Reporting suspicious transactions to the NZ Police.
In the ordinary course of affairs, I frequently commence companies for clients to trade their business.
I do not have a trust account so that at least makes my compliance better. I understand I will be the compliance officer and responsible for compliance as well as my systems being subject to audit.
I firstly need to be CDD and EDD aware! Customer Due Diligence and Enhanced customer due diligence
Who is targeted by EDD?
• A trust or another vehicle for holding personal assets
• A non-resident customer from a country that has insufficient AML/CFT systems or measures in place
• A company with nominee shareholders or shares in bearer form,
• A politically exposed person (PEP)
• Customers seeking to conduct a complex, unusually large transaction or unusual pattern of transactions that have no apparent or visible economic or lawful purpose
• Any other customer that you assess (based on your risk assessment and standard CDD) to be of high ML/TF risk,
• Customers seeking to use new and developing technologies or products that might favor anonymity

I am lucky as I do not start trusts and am not a trustee, however as with the past, I need to be acutely aware of the source of funds (as in the past) and customer identity!
I need a list of shady countries as things may not be as they seem.
I always have real shareholders so that’s not too bad.
I will avoid all politicians like the plaque! Anyway who trusts politicians!
I will avoid anyone who is being complexed… been there done that, got rid of 4 clients like that!
Anyone who wants to be anonymous will have to have a bloody good reason! In addition, if I notice things suddenly change in vanilla clients I must be EDD at all time!

I have to do a manual too… hopefully, my peer group will develop one! In addition, I will need an auditor of the manual and me! I guess the costs of starting a new company will have to bear that cost! Pity the next person who wants to own a dairy who would benefit from being a company, instead of $345.00 to start the company being charged $3450.00 to cover the cost of the audit!

What it boils down to is knowing my customers. I don’t think that the authorities are trying to impede business!
So when I on board a client I will need: You may have to provide documents confirming your name, birthdate and address:
• passport; or
• drivers’ license and bank card;

and
• bank statement or power bill
If you represent a company or trust, you may have to provide extra information like:
• evidence of who you’re acting for (that is, the beneficial owners who effectively control or benefit from the trust or company).
Simple as?

Andrew
One Half of the Anywhere Business Network