Reporting to the NZ Police Financial Intelligence Unit
Reporting suspicious activities and transactions
Data from the NZ Police Financial Intelligence Unit (FIU) show that the reporting entities we supervise submitted more than a third of all SARs received in the 12 months ending 30 June 2020. That indicates an increase in reporting from Department -supervised entities compared to the previous year.
Note that the Reserve Bank of New Zealand – rather than the Department – supervises banks, which carry out the highest volume of financial transactions.
For the reporting entities we supervise to make up such a high percentage of SARs shows that many are positively engaged in monitoring and reporting suspicious requests or transactions, helping detect criminal activity and preventing harm to our communities.
However, FIU data also shows that many Department supervised reporting entities, mostly law firms, accountants and real estate agents, are not registered for goAML with the FIU. We expect that all reporting entities register for goAML so they are able to report SARs and PTRs within the required timeframe.
Why reporting suspicious activity is importantFIU SAR Guideline
A key purpose of an AML/CFT programme is to detect money laundering and terrorism financing. The FIU relies on reporting entities to detect and report suspicious activity. A SAR should be submitted using the goAML tool.
A reporting entity must submit a SAR where there are objectively reasonable grounds to suspect a transaction or proposed transaction, a service or proposed service, is, or may be, relevant to the investigation or prosecution of criminal activity. The full definition of suspicious activity is found under section 39A of the Act.
The FIU analyses the SAR information and it may be used for criminal investigations and national security measures. SARs provide crucial information to assist the New Zealand Police and its partner agencies to investigate financial crime.
SARs are confidential. If a reporting entity submits a SAR about a customer or person, that person will not find out. This is to keep reporting entity staff safe and to ensure that any criminal investigations or security matters are not impeded.
To disclose information about a SAR, or the existence of a SAR, to a person that is the subject of it is known as “tipping-off”. This is a serious offence under the AML/CFT Act.
Suspicious activity reports by year
|SARs||Transaction based||Activity based|
|2018-2019 - All reporting entities total||11,658||495|
|2019-2020 - All reporting entities total||12,899||618|
|2018-2019 - DIA reporting entities||3,916||221|
|2019-2020 - DIA reporting entities||4,589||421|
|2018-2019 % (of all reports) submitted by DIA reporting entities||34%||45%|
|2019-2020 % (of all reports) submitted by DIA reporting entities||36%||68%|
Reporting prescribed transactions
A reporting entity must submit a PTR to the FIU for any large physical cash transaction of NZ$10,000 and over, and for any international wire transfer of NZ$1,000 and over (where it is an ordering or beneficiary institution in New Zealand).
A PTR must be submitted to the FIU through goAML within 10 days of the transaction.
PTRs help to build an intelligence picture across the entire financial system. In addition to SARs, PTRs add further transparency to the financial system by making certain ML/TF typologies even more difficult to hide, as well as improving the detection of organised crime, fraud and tax evasion.
Reporting to the Supervisor
All reporting entities supervised by the Department must complete an annual report of their risk assessment and AML/CFT programme. A reporting entity should use its annual AML/CFT report as a way to review and update the status of its risk assessment and AML/CFT programme.
The annual AML/CFT report helps the Department to understand how reporting entities meet their AML/CFT obligations, how they assess and mitigate their risk of ML/TF and how they manage their financial activities.
This year was the second year of reporting entities submitting their Annual AML/CFT report through AML Online. AML Online is a secure platform for reporting entities to engage with the Department online.
The following chart shows the proportion of reporting entities by sector who submitted their annual AML/CFT report on-time.