What is this?
Since the terrorist attacks on Christchurch mosques on 15 March 2019, New Zealand’s national terrorism threat level has been high – high threat levels means government agencies have assessed a terrorist attack, violent criminal behaviour, or violent protest activity as very likely.
Who should read this?
Everyone – this is important and we recommend you take action now. If your business is a New Zealand AML/CFT reporting entity, then you must take action on this guidance.
What action should we take?
We suggest you do three things now:
- Double check that you actually have an analysis of your business’ inherent terrorist financing (TF) in your existing Risk Assessment. If you don’t, do that right now. If you do, update it to include the new information the FIU has included in its paragraph titled Implications of Threat Level for Reporting Entities;
- Double check that you already have TF red flags and indicators included in your Programme so that staff know how to file Suspicious Property Reports (SPRs) when needed. If you don’t do that right now. If you do, update your TF red flag library to include the FIU’s new information in its paragraph titled SAR Guideline Indicators Relating to Terrorist Financing, Weapons Proliferation, and Security;
- Let your staff and board know that the New Zealand Police’s National Risk Assessment (NRA) is being updated to more specifically account for the increased risk of domestic terrorism in New Zealand. When new guidance is issued by the New Zealand Police or one of the AML/CFT Supervisors, you will need to review your Risk Assessment and Programme to see if your business’ inherent ML/TF risk profile has changed.
So you’re saying this is a big deal?
Yes. The attacks of 15/3 will impact the AML/CFT compliance regimes of all New Zealand businesses. This is not the sort of issue you want to fall behind on – act now.
Need help updating your AML/CFT Risk Assessment or Programme and building awareness among your staff? Email firstname.lastname@example.org now.