Anti-Money Laundering and Sanctions Compliance

Anti-Money Laundering and Sanctions Compliance

KPMG Forensic help clients understand how money launderers and the financiers of terrorism could be exploiting vulnerabilities in their organisations.

How could money launderers & financiers of terrorism exploit organisation vulnerabilities?

COVID-19: Why AML/CFT compliance officers should still be thinking about thier future independent audits. Read more here.


New Zealand’s Anti-Money Laundering and Countering Financing of Terrorism (AML/CFT) regime came into effect on 1 July 2013 for what are commonly referred to as ‘Phase 1’ entities (principally financial institutions and casino). The regime is being extended to ‘Phase 2’ entities meaning the obligations extend to ‘designated non-financial businesses and professions’ as follows: 

  • lawyers and conveyancers from 1 July 2018
  • accountants from 1 October 2018
  • real estate agents from 1 January 2019
  • high-value dealers* and the New Zealand Racing Board from 1 July 2019.

*high-value dealers are business that buy or sell specified article and transact in cash over a specified value. 

While the extension to additional sectors is the headline grabber for Phase 2 reform, regulatory changes will impact phase one entities with regulatory changes to drive efficiencies, extend reporting to suspicious activity and enhance information sharing.  

In addition to Phase 2 changes, Prescribed Transaction Reporting obligations commence on 1 November 2017.  PTR requirements obligate reporting entities who conduct a large cash transaction (>10k) or international wire transfer (>1k) to report the transaction and associated customer information to the NZ Police. 

Regulatory driven regime

The AML/CFT regime is driven by NZ’s international commitments to implement Financial Action Task Force recommendations. At its heart, is implementing actions that will help NZ combat money laundering and terrorist financing. 

As a reporting entity the failure to implement and maintain an effective AML/CFT risk assessment and programme can result regulatory intervention resulting in substantial monetary penalties, and reputational damage.  Supervisors are active in monitoring reporting entity compliance. 

Why choose KPMG?

It is therefore critical to have the right team on your side. KPMG AML specialists have worked with reporting entities across the supervised sector.  We believe having dedicated AML specialists best serves our clients to navigate the requirements and supervisory expectations without burying your business.  

Our team is focused on robust, real-world solutions based on our experience in New Zealand and internationally. We understand you want a manageable, pragmatic framework that works within your business – and is fully compliant with the expectations of your regulator.

A single, cost-effective resource.

We can deliver the full spectrum of services to support your AML/CFT Programme and Risk Assessment. We have the experience built through working with clients in New Zealand and internationally.

A pragmatic solution that’s proportionate to your risk.

You’re looking for a compliance framework that’s suited to your size and type of business. So we’ll ensure you cover everything you need – and nothing you don’t.

Our hands-on approach.

There’s nothing like experience on both sides of the fence. Our collective backgrounds include law, investigative policing and in-house compliance. We are all active members of the Association of Certified Anti-Money Laundering Specialists (ACAMS) which helps ensure we are up to speed with best practices and risks.

Our experience with sector supervisors.

We’ve built up a detailed knowledge of the best approach to dealing with regulators and supervisors – including the Reserve Bank of New Zealand, the Financial Markets Authority, the Department of Internal Affairs.

We can help you with:

Design and build of your AML/CFT Programme and Risk Assessment.

Together we’ll design a solution that addresses the actual risks and vulnerabilities within your organisation.  Our approach is to build a framework that is fit for purpose, sustainable and tailored to your risks.

Readiness and health checks.

Test it before you need it. We can undertake a gap analysis to ensure your Programme, Risk Assessment or components of concern are robust and in alignment to your obligations.


When things have gone wrong, we can help you to plan and carry out remediation of your Programme and Risk Assessment.

Audit your Programme and Risk Assessment.

We can help you through delivering limited or reasonable assurance engagements.

Responding to regulatory inspections and requests.

Prior to a visit or request from your sector supervisor, we can brief you on their expectations to give you a ‘no surprises’ approach to the inspection and provide you with peace of mind.

Technical advice

As dedicated specialists we have in-depth understanding of the requirements, industry practice and supervisory expectations.  We can assist you deal with ambiguity or efforts drive efficiencies into your compliance approach. 

Download our Services brochure for full details on our services.

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