AML - General Flashcards
1
Q
In what circumstances are accountants required to report large cash transactions of $10,000 or more or international wire transfers of $1,000 or more from October 1 2018?
A
When they are a reporting entity under AML.
2
Q
Where is the Financial Intelligence Unit located in New Zealand?
A
Within the New Zealand police.
3
Q
What acronym is used for the Financial Intelligence Unit?
A
FIU
4
Q
What does the FIU provide?
A
Financial Intelligence
5
Q
The FIU provides financial intelligence in relation to suspicious transactions, money laundering, the financing of terrorism and what?
A
Other serious offences.
6
Q
The FIU provides financial intelligence in relation to suspicious transactions, money laundering, other serious offences and what?
A
Financing of terrorism.
7
Q
The FIU provides financial intelligence in relation to suspicious transactions, financing of terrorism and other serious offences and what?
A
Money Laundering
8
Q
The FIU provides financial intelligence in relation to financing of terrorism and other serious offences and what?
A
Suspicious Transactions
9
Q
Where are the functions and powers of the FIU set out?
A
in the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT Act).
10
Q
What does the FIU help the New Zealand government fulfill its obligation to?
A
The Inter-Governmental Financial Action Task Force
11
Q
Other than the inter-governmental Financial Action Task Force and the prevention and detection of serious crime, what else does the FIU assist the New Zealand government to fulfill its obligation to?
A
The Government’s organised crime strategy.
12
Q
The FIU collects and collates information provided by whom?
A
External parties and reporting entities.
13
Q
Who does the FIU especially get information from?
A
The banks and other financial institutions
14
Q
After the required analysis, intelligence products are sent to other investigative and intelligence units within who?
A
Police, sector supervisors, domestic partner agencies and to relevant international agencies.
15
Q
Other than Suspicious transaction reports, suspicious property reports and border cash reports, what else is the main source of information for the FIU?
A
Prescribed transaction reports
16
Q
When did the FIU start collecting prescribed transaction reports from?
A
November 2017
17
Q
Other than Suspicious transaction reports, suspicious property reports and prescribed transaction reports, where else does what else is the main source of information for the FIU?
A
Border cash reports
18
Q
Other than Suspicious transaction reports, prescribed transaction reports and border cash reports, where else does what else is the main source of information for the FIU?
A
Suspicious property reports
19
Q
Other than Suspicious property reports, prescribed transaction reports and border cash reports, where else does what else is the main source of information for the FIU?
A
Suspicious transaction reports
20
Q
Other than the Reserve Bank of New Zealand and the Financial Markets Authority, who else monitors the reporting entities within different sectors?
A
The Department of Internal Affairs.
21
Q
What is a word which means a classification according to general type, especially in archaeology, psychology, or the social sciences?
A
Typology
22
Q
What is a typology?
A
A classification according to general type, especially in archaeology, psychology, or the social sciences.
23
Q
What typologies does the FIU produce?
A
Typologies of money laundering and financing of terrorism transactions.
24
Q
What are the typologies produced by the FIU, produced in?
A
A quarterly report.
25
What is the Egmont Group?
A united body of 155 Financial Intelligence Units (FIUs) from across the world.
26
What does the Egmont Group provide?
A platform for the secure exchange of expertise and financial intelligence to combat money laundering and terrorist financing.
27
When was the Egmont Group formed?
In 1995
28
How did the Egmont Group get its name?
From the Egmont Arenberg Palace in Brussels, where the first meeting took place.
29
What forms the bulk of the FIU?
The analytics team.
30
What does the NIA stand for under AML?
National Intelligence Application
31
Who uses the NIA under AML?
The police
32
How do the police use the NIA?
To determine details such as whether previous criminal history.
33
What is a STR under AML?
Suspicious transaction report
34
What is the acronym for Suspicious Transaction Report?
STR
35
What is a section 143A under AML?
An official request for information.
36
What is an official request for information under AML called?
A section 143A request.
37
Where are cash dogs used?
At the airport.
38
What are cash dogs used for?
Sniffing out people carrying large amounts of cash.
39
Are trusts considered a risk under AML?
Yes
40
When are trusts especially considered a risk under AML?
When there are overseas people involved.
41
What is a SAR under AML?
Suspicious Activity Report?
42
What is a PTR under AML?
A prescribed transaction report.
43
What are accountants allowed to do with respect to their clients? With respect to AML.
Ask them questions.
44
What are accountants not allowed to do with respect to their clients with respect to AML?
Tell them they’re going to file a report.
45
Why is an accountant telling their clients that they are going to file a report, illegal with respect to the AML?
Its considered to be ‘tipping off’.
46
What is an example of a legitimate question for accountants to ask their clients under AML?
What is the reason for their structure.
47
What is the TSA?
Terrorism Suppression Act.
48
What does ‘layering’ mean with regards to the AML?
The middle stages of money laundering.
49
What is a word for the middle stages of money laundering?
Layering
50
What is an AML / CFT Programme under section 5 of the AML / CFT Act?
A programme established under section 56(1) of the AML.
51
What are AML Requirements under section 5 of the AML / CFT Act?
Requirements set out in Part 2 of the AML Act.
52
What is an AML /CFT Supervisor in relation to a reporting entity?
The person referred to in section 130(1) who is responsible for supervising the reporting entity under parts 3 and 4.
53
What is the first type of reporting entity under section 5 of the AML / CFT Act?
A Casino
54
What is the second type of reporting entity under section 5 of the AML / CFT Act?
A designated non-financial business or profession.
55
What is the third type of reporting entity under section 5 of the AML / CFT Act?
A financial institution.
56
What is the fourth type of reporting entity under section 5 of the AML / CFT Act?
A high-value dealer.
57
What is the fifth type of reporting entity under section 5 of the AML / CFT Act?
The New Zealand Racing Board
58
Under part b) part i) of the definition of reporting entity, what type of person does a reporting entity also include?
A person or class of persons declared by regulations to be a reporting entity for the purposes of the AML Act.
59
Under part b) part ii) of the definition of reporting entity, what type of person does a reporting entity also include?
Any other person who is required by any other enactment to comply with the AML Act as if it were a reporting entity.
60
Under part c) of the definition of reporting entity, what type of person or class of persons is excluded from being a reporting entity?
Any person or class of persons declared by regulations not to be a reporting entity for the purposes of the AML Act.
61
What is an acronym which describes the types of businesses and professionals potentially considered reporting entities under AIM because of being considered a non-financial business or profession conducting activities in the ordinary course of business which come within the requirements of a reporting entity for AIM?
‘LCIART’
62
What is a potential method of remembering the acronym ‘LCIART referring to types of business coming within the requirements for AML’?
Large camels in a railway train
63
What does the ‘L’ stand for in LCIART?
Law Firm
64
What does the ‘C’ stand for in LCIART?
Conveyancing Practitioner
65
What does the ‘I’ stand for in LCIART?
Incorporated Conveyancing Firm
66
What does the ‘A’ stand for in LCIART?
Accounting Practice
67
What does the ‘R’ stand for in LCIART?
Real Estate Agents
68
What does the ‘T’ stand for in LCIART?
Trust and Company Service Provider
69
What acronym stands for the type of activities in the ordinary course of business which come within the requirements of AML?
FNRMRA
70
What is a potential method of remembering the acronym FNRMRA the type of activities in the ordinary course of business which come within the requirements of AML?
Friendly new rabbits munching red asparagus.
71
What does the ‘F’ stand for in FNRMRA?
Formation agents
72
What does the ‘N’ stand for in FNRMRA?
Nominee director. Nominee shareholder or trustee.
73
What does the first ‘R’ stand for in FNRMRA?
Registered Office
74
What does the ‘M’ stand for in FNRMRA?
Managing Client Funds
75
What does the second ‘R’ stand for in FNRMRA?
Real Estate Agency Work
76
What does the second ‘A’ stand for in FNRMRA?
Agent for Conveyancing
77
When does providing a registered office or business address not fit within the types of businesses and professionals potentially considered reporting entities under AML?
When that registered office or business address is ancillary to the provision of other services not coming within the definition of the requirements for AML.
78
What does managing client funds include and not include for the purposes of coming within AML?
It does not include sums paid as fees for professional services but does include managing of accounts, securities or other services.
79
What acronym describes transactions which come within the definition of AML even if not in the ordinary course of business when performed by a designated no financial business or profession?
RTTT
80
definition of AML even if not in the ordinary course of business when performed by a designated no financial business or profession?
Racing cars trailing touring trucks
81
What does the ‘R’ stand for in the AML acronym RTTT?
Real estate transactions
82
What does the first ‘T’ stand for in the AML acronym RTTT?
Transfer of beneficial interest in land or other real property.
83
What does the second ‘T’ stand for in the AML acronym RTTT?
Transactions in relation to buying or selling a business.
84
What does the third ‘T’ stand for in the AML acronym RTTT?
Transactions in relation to creating, operating and managing a legal person such as a company, and any other legal transaction.
85
What AML typologies involving accountants are considered to be a major risk by the FIU with major consequences of an increase?
Shell companies, nominees, trusts, 3rd parties etc
86
What is the first thing that accountants who are reporting entities required to do by 1 October 2018?
Appoint an AML / CFT Compliance Officer
87
What is the second thing that accountants who are reporting entities required to do by 1 October 2018?
Produce a risk assessment.
88
What is the second thing that accountants who are reporting entities required to do by 1 October 2018?.
Establish an AML/ EFT Programme
89
What is the first thing that that accountants who are reporting entities required to do as part of operations after 1 October 2018?
Vet and train employees.
90
What is the second thing that that accountants who are reporting entities required to do as part of operations after 1 October 2018?
Perform Customer Due Diligence.
91
What is the third thing that that accountants who are reporting entities required to do as part of operations after 1 October 2018?
Get an independent audit of Risk Assessment and AML / CFT Programme every two years.
92
What is the first thing that that accountants who are reporting entities required to do as part of reporting, after 1 October 2018?
Report suspicious activities and prescribed transactions.
93
What is the second thing that that accountants who are reporting entities required to do as part of reporting, after 1 October 2018?
File an annual report
94
What is the first reason it is necessary that AML applies to accountants?
Evidence based support from past and current cases.
95
What is the second reason it is necessary that AML applies to accountants?
Professional facilitators are a significant feature of serious criminal offending.
96
What is the third reason it is necessary that AML applies to accountants?
Professionals have vulnerabilities that criminals may take advantage of.
97
Other than as a form of investment, how are houses used by organised crime?
As ‘grow houses’.
98
What is required in this scenario?
An Accountant’s firm is the registered mailing and contact in New Zealand for:-
• Company ABC Limited based overseas in Panama;
• 4 directors;
• All directors are domiciled overseas.
* Do you know your Customer / client?
* Change in (Companies Act) legislation -requiring 1 director to reside in New Zealand unless he / she resides in Australia and is a director of a company incorporated in Australia.
99
What is required in this scenario?
• You have received a sum of money from a client;
• The client asks you to transfer some or all of the money to a third party;
• You transfer from your account to a third party.
* Do you know the origins of these funds?
| * Could you be inadvertently be drawn into a criminal matter.
100
What acronym could be used with regards to AML and Shell Companies?
LAALCS
101
How could the acronym LAALCS with regards to AML be remembered?
Large apes are launching coal ships.
102
What does the first L stand for in the acronym LAALCS to do with Shell Companies?
Large number of companies registered with the same office address.
103
What does the first A stand for in the acronym LAALCS to do with Shell Companies?
Address supplied is a “Virtual Office”.
104
What does the second A stand for in the acronym LAALCS to do with Shell Companies?
Accounts / facilities opened / operated by company formation agents.
105
What does the second L stand for in the acronym LAALCS to do with Shell Companies?
Lack of information regarding overseas directors / beneficiaries.
106
What does the C stand for in the acronym LAALCS to do with Shell Companies?
Complex ownership structures.
107
What does the S stand for in the acronym LAALCS to do with Shell Companies?
Structures where there is no apparent legitimate economic or other rationale.
108
What is the 1st obligation under AML?
AML /CFT Risk Assessment
109
What is the 2nd obligation under AML?
AML /CFT Compliance Programme
110
What is the 3rd obligation under AML?
AML /CFT Annual Report
111
What is the 4th obligation under AML?
Independent Audits
112
What are 5 tools for conducting staff vetting?
* Police Check
* Reference Check
* Qualification Check
* Social Media Check
* Credit Check
113
Where a higher level of risk is identified, what must be conducted?
Enhanced Customer due diligence
114
When enhanced customer due diligence must be conducted, what needs to be collected?
Information relating to the source of funds and or wealth of the Customer.
115
Once information has been collected as part of Customer due diligence, what must be done?
Reasonable steps must be taken to verify that information based on the level of risk identified for each Customer.
116
When reasonable steps are taken to verify information collected as part of due diligence, what should those steps be based on?
The level of risk identified for each Customer.
117
What is an acronym for Customer Due Diligence?
CDD
118
What is Customer due diligence / CDD?
The process of verifying information supplied by Customers.
119
What should be done with respect to enhanced CDD?
Customers requiring it should be identified and your staff should be made aware of these.
120
Once Customers requiring enhanced CDD have been identified, what should be done with respect to your staff?
Your staff should be made aware of which Customers require enhanced CDD.
121
What item is missing from this checklist?
Customer Checklist
1/ _______ or another vehicle for holding personal assets
2/ Foreign Politically Exposed Persons (PEPS) from a central watchlist.
3/ Non-NZ resident personnel from jurisdiction / country that has insufficient AML / CFT system in place.
4/ If a customer is known to come from a high-risk jurisdiction (known to deal in drugs / is corrupt or has ties to terrorism
5/ Entities with nominee shareholders or shares in bearer form.
Trusts
122
What item is missing from this checklist?
Customer Checklist
1/ Trusts or another vehicle for ___________________
2/ Foreign Politically Exposed Persons (PEPS) from a central watchlist.
3/ Non-NZ resident personnel from jurisdiction / country that has insufficient AML / CFT system in place.
4/ If a customer is known to come from a high-risk jurisdiction (known to deal in drugs / is corrupt or has ties to terrorism
5/ Entities with nominee shareholders or shares in bearer form.
Holding personal assets
123
What is an acronym for Politically Exposed Persons?
PEPS
124
Where is information about Foreign Politically Exposed Persons (PEPS) obtained from?
A Central watchlist
125
What item is missing from this checklist?
Customer Checklist
1/ Trusts or another vehicle for holding personal assets
2/ _____________________ from a central watchlist.
3/ Non-NZ resident personnel from jurisdiction / country that has insufficient AML / CFT systems in place.
4/ If a customer is known to come from a high-risk jurisdiction (known to deal in drugs / is corrupt or has ties to terrorism
5/ Entities with nominee shareholders or shares in bearer form.
Foreign Politically Exposed Persons (PEPS)
126
What items are missing from this checklist?
Customer Checklist
1/ Trusts or another vehicle for holding personal assets
2/ Foreign Politically Exposed Persons (PEPS) from a central watchlist.
3/___________________ from jurisdiction / country that has ____________ in place.
4/ If a customer is known to come from a high-risk jurisdiction (known to deal in drugs / is corrupt or has ties to terrorism
5/ Entities with nominee shareholders or shares in bearer form.
Non-NZ resident personnel
| has insufficient AML / CFT systems
127
What is considered a high-risk jurisdiction under AML?
One where dealing in drugs / corruption / ties to terrorism are common
128
What item is missing from this checklist?
Customer Checklist
1/ Trusts or another vehicle for holding personal assets
2/ Foreign Politically Exposed Persons (PEPS) from a central watchlist.
3/ Non NZ resident personnel from jurisdiction / country that has insufficient AML /CFT systems in place.
4/ __________________________________
5/ Entities with nominee shareholders or shares in bearer form.
If a customer is known to come from a high-risk jurisdiction (known to deal in drugs / is corrupt or has ties to terrorism
129
What item is missing from this checklist?
Customer Checklist
1/ Trusts or another vehicle for holding personal assets
2/ Foreign Politically Exposed Persons (PEPS) from a central watchlist.
3/ Non NZ resident personnel from jurisdiction / country that has insufficient AML /CFT systems in place.
4/ If a customer is known to come from a high-risk jurisdiction (known to deal in drugs / is corrupt or has ties to terrorism
5/ Entities with _____________ or shares in bearer form.
Nominee shareholders
130
What item is missing from this checklist?
Customer Checklist
1/ Trusts or another vehicle for holding personal assets
2/ Foreign Politically Exposed Persons (PEPS) from a central watchlist.
3/ Non NZ resident personnel from jurisdiction / country that has insufficient AML /CFT systems in place.
4/ If a customer is known to come from a high-risk jurisdiction (known to deal in drugs / is corrupt or has ties to terrorism
5/ Entities with nominee shareholders or__________________.
Shares in bearer form
131
Other than for the 5 types of Customer identified, when else is enhanced CDD required?
When a Customer seeks to conduct a complex, unusually large or unusual pattern of transactions. With no apparent economic or lawful purpose. and in particular situations where your entity determines that the level of risk requires it.
132
Where is information concerning whether a simplified CDD would be appropriate?
In the AML / CFT Act.
133
Give examples of entities for whom a simplified CDD is permitted.
govt departments, public bodies, registered banks. Companies listed on the stock exchange
134
Where does guidance come from for identifying suspicious activities with respect to AML /CFT?
Sector risk assessments and guidance material provided by the NZ FIU or supervisors
135
What is the acronym used in some countries for ‘Know Your Customer’?
KYC
136
What does the acronym CDD stand for?
Customer due diligence
137
What type of persons is CDD always conducted on?
Natural Persons
138
When verifying name, date of birth and residential address, what is required?
That original supporting documents are sighted and that a copy is signed and dated to evidence that verification has occurred.
139
Sophie, an accountant is signing up a Customer, Alexander who needs assistance with the sale of his business.
To verify his name, date of birth and address details, Sophie asks for formal identification. Alexander shows his passport and a bank statement with his address.
What must Sophie look for to ensure that the bank statement is a valid form of identification?
The statement is less than 12 months old and shows a residential address (not a PO Box).
140
What is a beneficial owner?
A person who owns and / or controls your customer
141
Generally, what is the first element of being a beneficial owner?
Owns more than 25% of the Customer (There may be several who fall into this category).
142
Generally, what is the second element of being a beneficial owner?
Has effective control over a Customer and acts on their behalf.
143
Generally, what is the third element of being a beneficial owner?
On whose behalf a transaction is conducted.
144
Other than non NZ-resident customer from a jurisdiction / country that ha insufficient AML /CFT systems or measures in place, what type of Customers are considered to be of a higher risk?
Foreign politically exposed persons (PEPS) from a central watch list.
145
Other than PEPS, what type of Customer is considered to be of a higher risk?
Non NZ-resident customer from a jurisdiction / country that ha insufficient AML /CFT systems or measures in place.
146
Other than PEPS and non NZ-resident customer from a jurisdiction / country that ha insufficient AML /CFT systems or measures in place, what types of Customer are considered to be of a higher risk?
Customers from a high risk jurisdiction / country (ie is known to deal in drugs, is corrupt or has ties to terrorism)
147
Other than overseas Customers what types of entities are considered to e of higher risk?
Entities with nominee shareholders of shares in barer form.
148
What is a term which means using family members or third parties?
fronting
149
Which is the missing red flag for these general types of red flag?
1. _____________________________________________
2. Defensive stance to questioning or reluctance to provide CDD information including proof of income / wealth;
3. Unrealistic wealth compared to client profile;
4. Unusual business or transactions eg cash intensive businesses such as bars, restaurants and nightclubs;
5. Two or more persons with the same identification;
6. One person using multiple identification documents.
Customers using family members or third parties (otherwise known as fronting);
150
Which is the missing red flag for these general types of red flag?
7. Customers using family members or third parties (otherwise known as fronting);
8. ____________________________________________
9. Unrealistic wealth compared to client profile;
10. Unusual business or transactions eg cash intensive businesses such as bars, restaurants and nightclubs;
11. Two or more persons with the same identification;
12. One person using multiple identification documents
Defensive stance to questioning or reluctance to provide CDD information including proof of income / wealth;
151
Which is the missing red flag for these general types of red flag?
13. Customers using family members or third parties (otherwise known as fronting);
14. Defensive stance to questioning or reluctance to provide CDD information including proof of income / wealth;
15. ___________________________________
16. Unusual business or transactions eg cash intensive businesses such as bars, restaurants and nightclubs;
17. Two or more persons with the same identification;
18. One person using multiple identification documents.
Unrealistic wealth compared to client profile;
152
Which is the missing red flag for these general types of red flag?
19. Customers using family members or third parties;
20. Defensive stance to questioning or reluctance to provide CDD information including proof of income / wealth;
21. Unrealistic wealth compared to client profile;
22. ___________________________
23. Two or more persons with the same identification;
24. One person using multiple identification documents.
Unusual business or transactions eg cash intensive businesses such as bars, restaurants and nightclubs;
153
Which is the missing red flag for these general types of red flag?
25. Customers using family members or third parties;
26. Defensive stance to questioning or reluctance to provide CDD information including proof of income / wealth;
27. Unrealistic wealth compared to client profile;
28. Unusual business or transactions eg cash intensive businesses such as bars, restaurants and nightclubs;
29. ________________________________
30. One person using multiple identification documents.
Two or more persons with the same identification;
154
Which is the missing red flag for these general types of red flag?
31. Customers using family members or third parties;
32. Defensive stance to questioning or reluctance to provide CDD information including proof of income / wealth;
33. Unrealistic wealth compared to client profile;
34. Unusual business or transactions eg cash intensive businesses such as bars, restaurants and nightclubs;
35. Two or more persons with the same identification;
36. ___________________________________________-.
One person using multiple identification documents.
155
Which is the missing red flag for these types of red flag for accountants?
1. __________________________________________________-
2. Clients using professional business or trust account, where large deposits are made;
3. Funds are received from foreign jurisdictions particularly where there is no connection between the jurisdiction and the client;
4. Overseas instructions from a client for no economic reason;
5. Client is not concerned about the level of the fees;
6. Client has a fast-growing real estate portfolio;
7. Purchaser is a company with complicated beneficial ownership;
8. Purchase amount is unusual compared to the appraised value or the previous purchase amount;
9. Client appears to have cash substantially above their means;
10. Client uses a virtual office
Using an agent or intermediary without obvious reason;
156
Which is the missing red flag for these types of red flag for accountants?
1. Using an agent or intermediary without obvious reason;
2. ____________________________________________
3. Funds are received from foreign jurisdictions particularly where there is no connection between the jurisdiction and the client;
4. Overseas instructions from a client for no economic reason;
5. Client is not concerned about the level of the fees;
6. Client has a fast-growing real estate portfolio;
7. Purchaser is a company with complicated beneficial ownership;
8. Purchase amount is unusual compared to the appraised value or the previous purchase amount;
9. Client appears to have cash substantially above their means;
10. Client uses a virtual office
Clients using professional business or trust account, where large deposits are made;
157
Which is the missing red flag for these types of red flag for accountants?
1. Using an agent or intermediary without obvious reason;
2. Clients using professional business or trust account, where large deposits are made;
3. _____________________________________
4. Overseas instructions from a client for no economic reason;
5. Client is not concerned about the level of the fees;
6. Client has a fast-growing real estate portfolio;
7. Purchaser is a company with complicated beneficial ownership;
8. Purchase amount is unusual compared to the appraised value or the previous purchase amount;
9. Client appears to have cash substantially above their means;
10. Client uses a virtual office
Funds are received from foreign jurisdictions particularly where there is no connection between the jurisdiction and the client;
158
Which is the missing red flag for these types of red flag for accountants?
1. Using an agent or intermediary without obvious reason;
2. Clients using professional business or trust account, where large deposits are made;
3. Funds are received from foreign jurisdictions particularly where there is no connection between the jurisdiction and the client;
4. ___________________________
5. Client is not concerned about the level of the fees;
6. Client has a fast-growing real estate portfolio;
7. Purchaser is a company with complicated beneficial ownership;
8. Purchase amount is unusual compared to the appraised value or the previous purchase amount;
9. Client appears to have cash substantially above their means;
10. Client uses a virtual office.
Overseas instructions from a client for no economic reason;
159
Which is the missing red flag for these types of red flag for accountants?
1. Using an agent or intermediary without obvious reason;
2. Clients using professional business or trust account, where large deposits are made;
3. Funds are received from foreign jurisdictions particularly where there is no connection between the jurisdiction and the client;
4. Overseas instructions from a client for no economic reason;
5. ___________________________________
6. Client has a fast-growing real estate portfolio;
7. Purchaser is a company with complicated beneficial ownership;
8. Purchase amount is unusual compared to the appraised value or the previous purchase amount;
9. Client appears to have cash substantially above their means;
10. Client uses a virtual office
Client is not concerned about the level of the fees;
160
Which is the missing red flag for these types of red flag for accountants?
1. Using an agent or intermediary without obvious reason;
2. Clients using professional business or trust account, where large deposits are made;
3. Funds are received from foreign jurisdictions particularly where there is no connection between the jurisdiction and the client;
4. Overseas instructions from a client for no economic reason;
5. Client is not concerned about the level of the fees;
6. ___________________________________
7. Purchaser is a company with complicated beneficial ownership;
8. Purchase amount is unusual compared to the appraised value or the previous purchase amount;
9. Client appears to have cash substantially above their means;
10. Client uses a virtual office
Client has a fast-growing real estate portfolio;
161
Which is the missing red flag for these types of red flag for accountants?
1. Using an agent or intermediary without obvious reason;
2. Clients using professional business or trust account, where large deposits are made;
3. Funds are received from foreign jurisdictions particularly where there is no connection between the jurisdiction and the client;
4. Overseas instructions from a client for no economic reason;
5. Client is not concerned about the level of the fees;
6. Client has a fast-growing real estate portfolio;
7. _____________________________________
8. Purchase amount is unusual compared to the appraised value or the previous purchase amount;
9. Client appears to have cash substantially above their means;
10. Client uses a virtual office
Purchaser is a company with complicated beneficial ownership;
162
Which is the missing red flag for these types of red flag for accountants?
1. Using an agent or intermediary without obvious reason;
2. Clients using professional business or trust account, where large deposits are made;
3. Funds are received from foreign jurisdictions particularly where there is no connection between the jurisdiction and the client;
4. Overseas instructions from a client for no economic reason;
5. Client is not concerned about the level of the fees;
6. Client has a fast-growing real estate portfolio;
7. Purchaser is a company with complicated beneficial ownership;
8. _____________________________________-
9. Client appears to have cash substantially above their means;
10. Client uses a virtual office
Purchase amount is unusual compared to the appraised value or the previous purchase amount;
163
Which is the missing red flag for these types of red flag for accountants?
1. Using an agent or intermediary without obvious reason;
2. Clients using professional business or trust account, where large deposits are made;
3. Funds are received from foreign jurisdictions particularly where there is no connection between the jurisdiction and the client;
4. Overseas instructions from a client for no economic reason;
5. Client is not concerned about the level of the fees;
6. Client has a fast-growing real estate portfolio;
7. Purchaser is a company with complicated beneficial ownership;
8. Purchase amount is unusual compared to the appraised value or the previous purchase amount;
9. _________________________________
10. Client uses a virtual office
Client appears to have cash substantially above their means;
164
Which is the missing red flag for these types of red flag for accountants?
1. Using an agent or intermediary without obvious reason;
2. Clients using professional business or trust account, where large deposits are made;
3. Funds are received from foreign jurisdictions particularly where there is no connection between the jurisdiction and the client;
4. Overseas instructions from a client for no economic reason;
5. Client is not concerned about the level of the fees;
6. Client has a fast-growing real estate portfolio;
7. Purchaser is a company with complicated beneficial ownership;
8. Purchase amount is unusual compared to the appraised value or the previous purchase amount;
9. Client appears to have cash substantially above their means;
10. ________________
Client uses a virtual office
165
Which is the missing red flag for these types of red flag for lawyers?
1. __________________________________________--;
2. Client requests that deposited funds are sent to a third parties or parties rather than returned to the client;
3. Client avoids personal contact without good reason;
4. Unusual manner of execution eg the deposit of funds for the purchase price occurs unusually early in the transaction and before the purchase price is agreed between parties;
5. Amount being deposited is large compared to the client’s modest income;
6. Surplus funds are deposited;
7. Back-to-back property transactions, which were out of sync with normal market dynamics – the purported value of each property increasing rapidly with each transaction;
8. Client changes legal advisor a number of times in a short period of time for no apparent reason;
9. The purchase price is paid entirely in cash;
10. Client has no proper identification papers;
11. Purported legal documentation is too simple for the relevant transaction;
12. Client’s connection with the jurisdiction is unclear;
13. No mention of the issue by the client initially followed by an over willingness to provide a lot of documentation;
14. Urgency in getting the deal done
Once funds are received into a trust account, the transaction is aborted
166
Which is the missing red flag for these types of red flag for lawyers?
1. Once funds are received into a trust account, the transaction is aborted;
2. _________________________________________;
3. Client avoids personal contact without good reason;
4. Unusual manner of execution eg the deposit of funds for the purchase price occurs unusually early in the transaction and before the purchase price is agreed between parties;
5. Amount being deposited is large compared to the client’s modest income;
6. Surplus funds are deposited;
7. Back-to-back property transactions, which were out of sync with normal market dynamics – the purported value of each property increasing rapidly with each transaction;
8. Client changes legal advisor a number of times in a short period of time for no apparent reason;
9. The purchase price is paid entirely in cash;
10. Client has no proper identification papers;
11. Purported legal documentation is too simple for the relevant transaction;
12. Client’s connection with the jurisdiction is unclear;
13. No mention of the issue by the client initially followed by an over willingness to provide a lot of documentation;
14. Urgency in getting the deal done
Client requests that deposited funds are sent to a third parties or parties rather than returned to the client
167
Which is the missing red flag for these types of red flag for lawyers?
1. Once funds are received into a trust account, the transaction is aborted;
2. Client requests that deposited funds are sent to a third parties or parties rather than returned to the client;
3. ______________________________________-;
4. Unusual manner of execution eg the deposit of funds for the purchase price occurs unusually early in the transaction and before the purchase price is agreed between parties;
5. Amount being deposited is large compared to the client’s modest income;
6. Surplus funds are deposited;
7. Back-to-back property transactions, which were out of sync with normal market dynamics – the purported value of each property increasing rapidly with each transaction;
8. Client changes legal advisor a number of times in a short period of time for no apparent reason;
9. The purchase price is paid entirely in cash;
10. Client has no proper identification papers;
11. Purported legal documentation is too simple for the relevant transaction;
12. Client’s connection with the jurisdiction is unclear;
13. No mention of the issue by the client initially followed by an over willingness to provide a lot of documentation;
14. Urgency in getting the deal done
Client avoids personal contact without good reason
168
Which is the missing red flag for these types of red flag for lawyers?
1. Once funds are received into a trust account, the transaction is aborted;
2. Client requests that deposited funds are sent to a third parties or parties rather than returned to the client;
3. Client avoids personal contact without good reason;
4. ______________________________________________________;
5. Amount being deposited is large compared to the client’s modest income;
6. Surplus funds are deposited;
7. Back-to-back property transactions, which were out of sync with normal market dynamics – the purported value of each property increasing rapidly with each transaction;
8. Client changes legal advisor a number of times in a short period of time for no apparent reason;
9. The purchase price is paid entirely in cash;
10. Client has no proper identification papers;
11. Purported legal documentation is too simple for the relevant transaction;
12. Client’s connection with the jurisdiction is unclear;
13. No mention of the issue by the client initially followed by an over willingness to provide a lot of documentation;
14. Urgency in getting the deal done
Unusual manner of execution eg the deposit of funds for the purchase price occurs unusually early in the transaction and before the purchase price is agreed between
169
Which is the missing red flag for these types of red flag for lawyers?
1. Once funds are received into a trust account, the transaction is aborted;
2. Client requests that deposited funds are sent to a third parties or parties rather than returned to the client;
3. Client avoids personal contact without good reason;
4. Unusual manner of execution eg the deposit of funds for the purchase price occurs unusually early in the transaction and before the purchase price is agreed between parties;
5. ______________________________________;
6. Surplus funds are deposited;
7. Back-to-back property transactions, which were out of sync with normal market dynamics – the purported value of each property increasing rapidly with each transaction;
8. Client changes legal advisor a number of times in a short period of time for no apparent reason;
9. The purchase price is paid entirely in cash;
10. Client has no proper identification papers;
11. Purported legal documentation is too simple for the relevant transaction;
12. Client’s connection with the jurisdiction is unclear;
13. No mention of the issue by the client initially followed by an over willingness to provide a lot of documentation;
14. Urgency in getting the deal done
Amount being deposited is large compared to the client’s modest income
170
Which is the missing red flag for these types of red flag for lawyers?
1. Once funds are received into a trust account, the transaction is aborted;
2. Client requests that deposited funds are sent to a third parties or parties rather than returned to the client;
3. Client avoids personal contact without good reason;
4. Unusual manner of execution eg the deposit of funds for the purchase price occurs unusually early in the transaction and before the purchase price is agreed between parties;
5. Amount being deposited is large compared to the client’s modest income;
6. ____________________________;
7. Back-to-back property transactions, which were out of sync with normal market dynamics – the purported value of each property increasing rapidly with each transaction;
8. Client changes legal advisor a number of times in a short period of time for no apparent reason;
9. The purchase price is paid entirely in cash;
10. Client has no proper identification papers;
11. Purported legal documentation is too simple for the relevant transaction;
12. Client’s connection with the jurisdiction is unclear;
13. No mention of the issue by the client initially followed by an over willingness to provide a lot of documentation;
14. Urgency in getting the deal done
Surplus funds are deposited
171
Which is the missing red flag for these types of red flag for lawyers?
1. Once funds are received into a trust account, the transaction is aborted;
2. Client requests that deposited funds are sent to a third parties or parties rather than returned to the client;
3. Client avoids personal contact without good reason;
4. Unusual manner of execution eg the deposit of funds for the purchase price occurs unusually early in the transaction and before the purchase price is agreed between parties;
5. Amount being deposited is large compared to the client’s modest income;
6. Surplus funds are deposited;
7. ________________________________________;
8. Client changes legal advisor a number of times in a short period of time for no apparent reason;
9. The purchase price is paid entirely in cash;
10. Client has no proper identification papers;
11. Purported legal documentation is too simple for the relevant transaction;
12. Client’s connection with the jurisdiction is unclear;
13. No mention of the issue by the client initially followed by an over willingness to provide a lot of documentation;
14. Urgency in getting the deal done
Back-to-back property transactions, which were out of sync with normal market dynamics – the purported value of each property increasing rapidly with each transaction;
172
Which is the missing red flag for these types of red flag for lawyers?
1. Once funds are received into a trust account, the transaction is aborted;
2. Client requests that deposited funds are sent to a third parties or parties rather than returned to the client;
3. Client avoids personal contact without good reason;
4. Unusual manner of execution eg the deposit of funds for the purchase price occurs unusually early in the transaction and before the purchase price is agreed between parties;
5. Amount being deposited is large compared to the client’s modest income;
6. Surplus funds are deposited;
7. Back-to-back property transactions, which were out of sync with normal market dynamics – the purported value of each property increasing rapidly with each transaction;
8. ___________________________________
9. The purchase price is paid entirely in cash;
10. Client has no proper identification papers;
11. Purported legal documentation is too simple for the relevant transaction;
12. Client’s connection with the jurisdiction is unclear;
13. No mention of the issue by the client initially followed by an over willingness to provide a lot of documentation;
14. Urgency in getting the deal done
Client changes legal advisor a number of times in a short period of time for no apparent reason
173
Which is the missing red flag for these types of red flag for lawyers?
1. Once funds are received into a trust account, the transaction is aborted;
2. Client requests that deposited funds are sent to a third parties or parties rather than returned to the client;
3. Client avoids personal contact without good reason;
4. Unusual manner of execution eg the deposit of funds for the purchase price occurs unusually early in the transaction and before the purchase price is agreed between parties;
5. Amount being deposited is large compared to the client’s modest income;
6. Surplus funds are deposited;
7. Back-to-back property transactions, which were out of sync with normal market dynamics – the purported value of each property increasing rapidly with each transaction;
8. Client changes legal advisor a number of times in a short period of time for no apparent reason;
9. _______________________________;
10. Client has no proper identification papers;
11. Purported legal documentation is too simple for the relevant transaction;
12. Client’s connection with the jurisdiction is unclear;
13. No mention of the issue by the client initially followed by an over willingness to provide a lot of documentation;
14. Urgency in getting the deal done
The purchase price is paid entirely in cash
174
Which is the missing red flag for these types of red flag for lawyers?
1. Once funds are received into a trust account, the transaction is aborted;
2. Client requests that deposited funds are sent to a third parties or parties rather than returned to the client;
3. Client avoids personal contact without good reason;
4. Unusual manner of execution eg the deposit of funds for the purchase price occurs unusually early in the transaction and before the purchase price is agreed between parties;
5. Amount being deposited is large compared to the client’s modest income;
6. Surplus funds are deposited;
7. Back-to-back property transactions, which were out of sync with normal market dynamics – the purported value of each property increasing rapidly with each transaction;
8. Client changes legal advisor a number of times in a short period of time for no apparent reason;
9. The purchase price is paid entirely in cash;
10. ________________________;
11. Purported legal documentation is too simple for the relevant transaction;
12. Client’s connection with the jurisdiction is unclear;
13. No mention of the issue by the client initially followed by an over willingness to provide a lot of documentation;
14. Urgency in getting the deal done
Client has no proper identification papers
175
Which is the missing red flag for these types of red flag for lawyers?
1. Once funds are received into a trust account, the transaction is aborted;
2. Client requests that deposited funds are sent to a third parties or parties rather than returned to the client;
3. Client avoids personal contact without good reason;
4. Unusual manner of execution eg the deposit of funds for the purchase price occurs unusually early in the transaction and before the purchase price is agreed between parties;
5. Amount being deposited is large compared to the client’s modest income;
6. Surplus funds are deposited;
7. Back-to-back property transactions, which were out of sync with normal market dynamics – the purported value of each property increasing rapidly with each transaction;
8. Client changes legal advisor a number of times in a short period of time for no apparent reason;
9. The purchase price is paid entirely in cash;
10. Client has no proper identification papers;
11. ____________________________________;
12. Client’s connection with the jurisdiction is unclear;
13. No mention of the issue by the client initially followed by an over willingness to provide a lot of documentation;
14. Urgency in getting the deal done
Purported legal documentation is too simple for the relevant transaction
176
Which is the missing red flag for these types of red flag for lawyers?
1. Once funds are received into a trust account, the transaction is aborted;
2. Client requests that deposited funds are sent to a third parties or parties rather than returned to the client;
3. Client avoids personal contact without good reason;
4. Unusual manner of execution eg the deposit of funds for the purchase price occurs unusually early in the transaction and before the purchase price is agreed between parties;
5. Amount being deposited is large compared to the client’s modest income;
6. Surplus funds are deposited;
7. Back-to-back property transactions, which were out of sync with normal market dynamics – the purported value of each property increasing rapidly with each transaction;
8. Client changes legal advisor a number of times in a short period of time for no apparent reason;
9. The purchase price is paid entirely in cash;
10. Client has no proper identification papers;
11. Purported legal documentation is too simple for the relevant transaction;
12. ________________________________;
13. No mention of the issue by the client initially followed by an over willingness to provide a lot of documentation;
14. Urgency in getting the deal done
Client’s connection with the jurisdiction is unclear;
177
Which is the missing red flag for these types of red flag for lawyers?
15. Once funds are received into a trust account, the transaction is aborted;
16. Client requests that deposited funds are sent to a third parties or parties rather than returned to the client;
17. Client avoids personal contact without good reason;
18. Unusual manner of execution eg the deposit of funds for the purchase price occurs unusually early in the transaction and before the purchase price is agreed between parties;
19. Amount being deposited is large compared to the client’s modest income;
20. Surplus funds are deposited;
21. Back-to-back property transactions, which were out of sync with normal market dynamics – the purported value of each property increasing rapidly with each transaction;
22. Client changes legal advisor a number of times in a short period of time for no apparent reason;
23. The purchase price is paid entirely in cash;
24. Client has no proper identification papers;
25. Purported legal documentation is too simple for the relevant transaction;
26. Client’s connection with the jurisdiction is unclear;
27. _____________________________________
28. Urgency in getting the deal done
No mention of the issue by the client initially followed by an over willingness to provide a lot of documentation;
178
Which is the missing red flag for these types of red flag for lawyers?
1. Once funds are received into a trust account, the transaction is aborted;
2. Client requests that deposited funds are sent to a third parties or parties rather than returned to the client;
3. Client avoids personal contact without good reason;
4. Unusual manner of execution eg the deposit of funds for the purchase price occurs unusually early in the transaction and before the purchase price is agreed between parties;
5. Amount being deposited is large compared to the client’s modest income;
6. Surplus funds are deposited;
7. Back-to-back property transactions, which were out of sync with normal market dynamics – the purported value of each property increasing rapidly with each transaction;
8. Client changes legal advisor a number of times in a short period of time for no apparent reason;
9. The purchase price is paid entirely in cash;
10. Client has no proper identification papers;
11. Purported legal documentation is too simple for the relevant transaction;
12. Client’s connection with the jurisdiction is unclear;
13. No mention of the issue by the client initially followed by an over willingness to provide a lot of documentation;
14. _________________________
Urgency in getting the deal done
179
Give an example of what could be used to get money into the financial system, that many NZ families have.
A trust
180
Phase two of the AML /CFT Act closes the ___________ available to money launders and helps to increase faith in NZ’s financial system
Loopholes
181
Phase two of the AML /CFT Act closes the loopholes available to __________ and helps to increase faith in NZ’s financial system.
Money launderers
182
Phase two of the AML /CFT Act closes the loopholes available to money launders and helps to increase _______ in NZ’s financial system.
Faith
183
Phase two of the AML /CFT Act closes the loopholes available to money launders and helps to increase faith in NZ’s ______________
Financial system.
184
What does FATF stand for with regards to AML /CFT?
Financial Action Task Force
185
______________ was the first country to formalise measures in an effort to counter money laundering and financing of terrorism back in 2001. Australia and the UK followed shortly after. The Financial Action Task Force or FATF then asked NZ to conduct an extensive review of its financial systems. This review let to the AML Act 2009. This Act came into effect on 30 June 2013. Phase 2 of the legislation came into force on 10 August 2017 through the amendment bill capturing lawyers from 1 July 2018 and accountants from 1 October 2018.
The United States
186
The United States was the first country to formalise measures in an effort to counter money laundering and financing of terrorism back in ______. Australia and the UK followed shortly after. The Financial Action Task Force or FATF then asked NZ to conduct an extensive review of its financial systems. This review let to the AML Act 2009. This Act came into effect on 30 June 2013. Phase 2 of the legislation came into force on 10 August 2017 through the amendment bill capturing lawyers from 1 July 2018 and accountants from 1 October 2018.
2001
187
The United States was the first country to formalise measures in an effort to counter money laundering and financing of terrorism back in 2001. Australia and the UK followed shortly after. The _____________ or FATF then asked NZ to conduct an extensive review of its financial systems. This review let to the AML Act 2009. This Act came into effect on 30 June 2013. Phase 2 of the legislation came into force on 10 August 2017 through the amendment bill capturing lawyers from 1 July 2018 and accountants from 1 October 2018.
Financial Action Task Force
188
The United States was the first country to formalise measures in an effort to counter money laundering and financing of terrorism back in 2001. Australia and the UK followed shortly after. The Financial Action Task Force or FATF then asked NZ to conduct an extensive review of its financial systems. This review let to __________. This Act came into effect on 30 June 2013. Phase 2 of the legislation came into force on 10 August 2017 through the amendment bill capturing lawyers from 1 July 2018 and accountants from 1 October 2018.
the AML Act 2009
189
The United States was the first country to formalise measures in an effort to counter money laundering and financing of terrorism back in 2001. Australia and the UK followed shortly after. The Financial Action Task Force or FATF then asked NZ to conduct an extensive review of its financial systems. This review let to the AML Act 2009. This Act came into effect on _________. Phase 2 of the legislation came into force on 10 August 2017 through the amendment bill capturing lawyers from 1 July 2018 and accountants from 1 October 2018.
30 June 2013
190
The United States was the first country to formalise measures in an effort to counter money laundering and financing of terrorism back in 2001. Australia and the UK followed shortly after. The Financial Action Task Force or FATF then asked NZ to conduct an extensive review of its financial systems. This review let to the AML Act 2009. This Act came into effect on 30 June 2013. _______ of the legislation came into force on 10 August 2017 through the amendment bill capturing lawyers from 1 July 2018 and accountants from 1 October 2018.
Phase 2
191
The United States was the first country to formalise measures in an effort to counter money laundering and financing of terrorism back in 2001. Australia and the UK followed shortly after. The Financial Action Task Force or FATF then asked NZ to conduct an extensive review of its financial systems. This review let to the AML Act 2009. This Act came into effect on 30 June 2013. Phase 2 of the legislation came into force on __________ through the amendment bill capturing lawyers from 1 July 2018 and accountants from 1 October 2018.
10 August 2017
192
The United States was the first country to formalise measures in an effort to counter money laundering and financing of terrorism back in 2001. Australia and the UK followed shortly after. The Financial Action Task Force or FATF then asked NZ to conduct an extensive review of its financial systems. This review let to the AML Act 2009. This Act came into effect on 30 June 2013. Phase 2 of the legislation came into force on 10 August 2017 through the ___________ capturing lawyers from 1 July 2018 and accountants from 1 October 2018.
amendment bill
193
The United States was the first country to formalise measures in an effort to counter money laundering and financing of terrorism back in 2001. Australia and the UK followed shortly after. The Financial Action Task Force or FATF then asked NZ to conduct an extensive review of its financial systems. This review let to the AML Act 2009. This Act came into effect on 30 June 2013. Phase 2 of the legislation came into force on 10 August 2017 through the amendment bill capturing ________ from 1 July 2018 and accountants from 1 October 2018.
lawyers
194
The United States was the first country to formalise measures in an effort to counter money laundering and financing of terrorism back in 2001. Australia and the UK followed shortly after. The Financial Action Task Force or FATF then asked NZ to conduct an extensive review of its financial systems. This review let to the AML Act 2009. This Act came into effect on 30 June 2013. Phase 2 of the legislation came into force on 10 August 2017 through the amendment bill capturing lawyers from __________ and accountants from 1 October 2018.
1 July 2018
195
The United States was the first country to formalise measures in an effort to counter money laundering and financing of terrorism back in 2001. Australia and the UK followed shortly after. The Financial Action Task Force or FATF then asked NZ to conduct an extensive review of its financial systems. This review let to the AML Act 2009. This Act came into effect on 30 June 2013. Phase 2 of the legislation came into force on 10 August 2017 through the amendment bill capturing lawyers from 1 July 2018 and __________ from 1 October 2018.
Accountants
196
The United States was the first country to formalise measures in an effort to counter money laundering and financing of terrorism back in 2001. Australia and the UK followed shortly after. The Financial Action Task Force or FATF then asked NZ to conduct an extensive review of its financial systems. This review let to the AML Act 2009. This Act came into effect on 30 June 2013. Phase 2 of the legislation came into force on 10 August 2017 through the amendment bill capturing lawyers from 1 July 2018 and accountants from ____________.
1 October 2018
197
NZ’s govt introduced the AML Act to close money laundering loop holes and rebuild the countries financial reputation. The capture of lawyers and accountants under the Act ensures ongoing compliance with international recommendations and follows other jurisdictions such as the UK in capturing these professions.
money laundering
198
NZ’s govt introduced the AML Act to close money laundering loop holes and rebuild the countries financial reputation. The capture of lawyers and accountants under the Act ensures ongoing compliance with international recommendations and follows other jurisdictions such as the _____ in capturing these professions.
UK
199
NZ’s govt introduced the ________to close money laundering loop holes and rebuild the countries financial reputation. The capture of lawyers and accountants under the Act ensures ongoing compliance with international recommendations and follows other jurisdictions such as the UK in capturing these professions.
AML Act
200
Under phase 1 there were approximately ________companies listed as reporting entities
2000
201
Under phase 1 there were approximately 2000 companies listed as _____________
Reporting entities
202
Estimated that under phase 2 an additional_____________ businesses will be reporting entities. All phase 2 entities are supervised by the DIA.
7000-8000
203
Estimated that under phase 2 an additional 7000-8000 __________ will be reporting entities. All phase 2 entities are supervised by the DIA
businesses
204
Estimated that under phase 2 an additional 7000-8000 businesses will be ___________. All phase 2 entities are supervised by the DIA.
reporting entities
205
Estimated that under phase 2 an additional 7000-8000 businesses will be reporting entities. All phase 2 entities are supervised by the _______.
DIA
206
The Act sets out ___________ that reporting entities must meet but leaves it to the entity to decide how these obligations will be met based on the level of risk an entity faces. To mitigate such risks an internal compliance officer must be assigned to meet the 4 obligations as shown on screen.
broad obligations
207
The Act sets out broad obligations that reporting entities must meet but ____________ to decide how these obligations will be met based on the level of risk an entity faces. To mitigate such risks an internal compliance officer must be assigned to meet the 4 obligations as shown on screen.(attachment)
leaves it to the entity
208
The Act sets out broad obligations that reporting entities must meet but leaves it to the entity to decide how these obligations will be met based on _____________ an entity faces. To mitigate such risks an internal compliance officer must be assigned to meet the 4 obligations as shown on screen.(
the level of risk
209
The Act sets out broad obligations that reporting entities must meet but leaves it to the entity to decide how these obligations will be met based on the level of risk an entity faces. To mitigate such risks an __________________must be assigned to meet the 4 obligations as shown on screen
internal compliance officer
210
A ____________is one of the first documents an entity must create. It needs to be a written document, and include the 3 components as listed on screen (What is a risk assessment slide - attachment)
risk assessment
211
A ____________ outlines processes to minimize risks identified in the risk assessment. It must also include policies, procedures and controls for carrying out customer due diligence and for identifying suspicious activity, reporting and maintaining customer records. Further processes also need to be set out for staff training, staff vetting, governance, and assurance. These areas of compliance are explored in further detail in module 2.
compliance programme
212
A compliance programme outlines processes to minimize risks identified in the risk assessment. It must also include ______________ for carrying out customer due diligence and for identifying suspicious activity, reporting and maintaining customer records. Further processes also need to be set out for staff training, staff vetting, governance, and assurance. These areas of compliance are explored in further detail in module 2.
policies, procedures and controls
213
An _____________ filed each August must answer questions relating to 4 broad topics as listed on screen. The Information from the ________________s tells Supervisors how entities are managing in meeting requirement of the Act.
Annual Report
214
An Annual Report filed each _____________ must answer questions relating to 4 broad topics as listed on screen. The Information from the Annual Reports tells Supervisors how entities are managing in meeting requirement of the Act.
August
215
An Annual Report filed each August must answer questions relating to 4 broad topics as listed on screen. The Information from the Annual Reports tells ____________how entities are managing in meeting requirement of the Act.
Supervisors
216
An independent audit must be carried out every two years or as requested by ___________. An auditor needs to have appropriate AML /CFT expertise and needs to be independent meaning someone who has not been involved in the development of your documentation
your supervisor
217
An independent audit must be carried out every two years or as requested by your supervisor. An auditor needs to have ______________ and needs to be independent meaning someone who has not been involved in the development of your documentation.
appropriate AML /CFT expertise
218
An independent audit must be carried out every two years or as requested by your supervisor. An auditor needs to have appropriate AML /CFT expertise and needs to be ________ meaning someone who has not been involved in the development of your documentation.
Independent
219
An independent audit must be carried out every two years or as requested by your supervisor. An auditor needs to have appropriate AML /CFT expertise and needs to be independent meaning someone who has not been involved in the _____________________________.
development of your documentation
220
What is the focus with respect to terrorist financing?
Preventing the criminal activity from occurring
221
What was New Zealand removed from by the European Union in May 2012?
The banking and corporate “White List”.
222
Why did the European Union remove New Zealand from the prestigious banking and corporate “White List” in May 2012?
Because of weak money laundering and terrorism financing controls.
223
What was the case which led to New Zealand being removed from the prestigious banking and corporate “White List” in May 2012?
New Zealand was implicated in a firearms smuggling ring operated from Latvia. The Latvians manufactured then stored millions of dollars’ worth of firearms in Thailand, all through two registered New Zealand companies.
224
New Zealand was implicated in a _____________ ring operated from Latvia. The Latvians manufactured then stored millions of dollars’ worth of firearms in Thailand, all through two registered New Zealand companies
firearms smuggling ring
225
New Zealand was implicated in a firearms smuggling ring operated from _______. The _______ manufactured then stored millions of dollars’ worth of firearms in Thailand, all through two registered New Zealand companies
Latvia Latvians
226
New Zealand was implicated in a firearms smuggling ring operated from Latvia. The Latvians manufactured then stored millions of dollars’ worth of firearms in _______, all through two registered New Zealand companies
Thailand
227
New Zealand was implicated in a firearms smuggling ring operated from Latvia. The Latvians manufactured then stored millions of dollars’ worth of firearms in Thailand, all through two ____________.
registered New Zealand companies
228
Money laundering occurs_________ the illegal funds have been generated.
after
229
What is the first phase of money laundering?
Placement
230
In what phase is it easiest to detect money laundering?
The placement phase
231
Why is it easiest to detect money laundering during the placement phase?
The funds are closest to the source.
232
What is the final phase of money laundering?
Integration
233
What does integration involved when talking about money laundering?
Introducing the money into the economy so that it appears as a “clean” or legitimate source of funds.
234
What is the first phase of an AML /CFT risk assessment?
Identify the risks faced by the entity.
235
What is the second phase of an AML /CFT risk assessment?
Describe how the entity will ensure the Assessment remains current.
236
What is the third phase of an AML /CFT risk assessment?
Enable the entity to determine the level of risk involved in relation to obligations under the Act.
237
Criminals may seek to ___________ cash into the professional’s trust account.
place
238
At the layering and integration stages, lawyers and accountants can provide the ___________ to create legal entities and arrangements to obscure ownership of assets and also assist in transferring those assets such as business and real estate.
“know-how”
239
At the layering and integration stages, lawyers and accountants can provide the “know-how” to create legal entities and arrangements to _________ ownership of assets and also assist in transferring those assets such as business and real estate.
obscure
240
At the layering and _________ stages, lawyers and accountants can provide the “know-how” to create legal entities and arrangements to obscure ownership of assets and also assist in transferring those assets such as business and real estate.
integration
241
When is the AML /CFT annual Report required to be filed by?
31 August each year
242
Who is responsible for filing the AML /CFT annual Report?
Internal Compliance Officer (attachment
243
Must the AML /CFT Risk Assessment be written?
Yes
244
Who must the AML /CFT Risk Assessment be maintained by?
A Compliance officer
245
```
An AML / CFT compliance Programme must include:-
• Customer due diligence (CDD);
• Staff Training;
• Staff Vetting;
• A__________ m__________
```
Account Monitoring
246
Must the AML /CFT Compliance Programme be written?
Yes
247
Are client credit checks required as part of the AML /CFT Compliance Programme?
No
248
CDD (for AML) is always conducted on n__________ p________
Natural persons
249
______________ of interest in land or other real property
Transfer
250
Transfer ____________ in land or other real property
of interest
251
Transfer of interest _____________ or other real property
in land
252
Transfer of _______________ or other real property
of interest in land
253
Transfer of interest in land ____________________
or other real property
