What is this?

From 1 August 2019, businesses that sell a certain type of product known as high value dealers (HVDs), and accept cash payments for these products above a threshold, will have some AML/CFT obligations.

Who should read this?

Reporting entities with HVDs as third party agents in their businesses, HVDs as customers, and those of you who just like to always know what’s going on in the New Zealand AML/CFT scene.

What does this mean in a nutshell?

Very little. HVDs have a “reduced” list of AML/CFT compliance requirements and even then only need to do those if they intend on accepting payments in cash over a yet-to-be-decided threshold. It seems that when a HVD has a policy of not accepting cash over that threshold, they have no AML/CFT requirements.

It sounds like you have an opinion that you’re angling to share?

So glad you asked, yes. This Factsheet says it is optional for HVDs to submit suspicious activity reports (SARs) to the New Zealand Police.

Since 2013, the AML/CFT Supervisors and Police have stressed to all Phase 1 and Phase 2 entities that the filing of SARs is the whole point of this expensive and painful AML/CFT compliance regime, and now it is optional for one sector?

In our opinion, this compromises the integrity of the purpose of the AML/CFT Act. Bizarre.