What is this?
The New Zealand Financial Intelligence Unit (FIU) and Ministry of Justice recently took the unusual measure of issuing a statement to New Zealand reporting entities. They advised reporting entities to give “special attention to business relationships and transactions” relating to:
- Democratic People’s Republic of Korea (DPRK), known colloquially as North Korea; and
In their statement, they additionally advised reporting entities to “take into account”:
- United States Treasury guidelines that discuss the current scope of US financial and banking sanctions recently lifted against non-US financial institutions;
- an additional document updated by the FATF on 22 February 2019: Improving Global AML/CFT Compliance: On-going Process in which FATF has identified jurisdictions that have strategic AML/CFT deficiencies. They are the Bahamas, Botswana, Cambodia, Ethiopia, Ghana, Pakistan, Serbia, Sri Lanka, Syria, Trinidad and Tobago, Tunisia and Yemen.
Where did you find this?
We stumbled upon this statement on a random page on the FIU website that we didn’t know existed, here.
Makes you wonder what other important, binding regulatory guidance is lurking around the New Zealand AML/CFT Supervisors’ various web pages…
Does this impact me?
If you’re currently doing any sort of business with North Korea and/or Iran, you should be asking this of your local international trade lawyer, not looking for guidance in a newsletter. But, yes if you’re dealing with North Korea and Iran you need to be expert in the scope of current US sanctions against these countries.
If you have any customers, transactions, or general dealings with the countries FATF have identified as having strategic AML/CFT deficiencies, then you need to include this updated information in your Risk Assessment and determine the extent to which your countries ML/TF risk profile is impacted.
Everybody will benefit form using this as an opportunity to refresh their memory of the Countries Guideline issued by the AML/CFT Supervisors.
So nothing to see here if I don’t deal with these countries then?
Right now, nothing to see here. But you should take this as a heads up that the FIU and Ministry of Justice are issuing hard-to-find guidance that you are legally bound by.
We’re doing our best to find it and bring it to your attention – do your fellow reporting entities a solid and forward it on if you think they might be affected.
Email firstname.lastname@example.org if you need to update the countries risk in your AML/CFT Risk Assessment.