Record-keeping is a vital part of your AML/CFT programme, as it is the source of truth for all your activities. Without good records you cannot prove to external auditors and the Supervisors that your company is doing AML and that you are compliant.
On August 2021, the FMA issued its AML/CFT Monitoring Insight Report for 2018 to 2021. The Director of Supervision noted that the AML/CFT regime has now matured to such an extent that the FMA has less tolerance for AML non-compliance. In other words, businesses are expected to have a strong handle on meeting their AML/CFT obligations.
We can expect this view to be true for the other Supervisors: DIA and RBNZ.
