Suspicious Activities and Transactions Reports

Changes to the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT Act) and regulations bring in new requirements for reporting entities to report suspicious activity as well as suspicious transactions to the New Zealand Financial Intelligence Unit (FIU).

Currently, reporting entities only need to report suspicious transactions to the FIU, however, reporting entities may notice suspicious activity that could also provide valuable intelligence, even if a transaction is not completed.

New Guideline: Suspicious Activity Reports (SAR)

The FIU have issued a Suspicious Activity Reporting Guideline to help clarify the obligation to report SARs under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT Act).

Reporting Suspicious Activities

(Commencement date – 1 July 2018)

Suspicious activities will need to be reported to the FIU from 1 July 2018.

Businesses introduced under “Phase 2” of the AML/CFT Act 2009 will need to start reporting suspicious activities from the date they must start to comply with the Act. Further information is available on the Ministry of Justice website, including the commencement dates for “Phase 2” businesses.

How do I submit Suspicious Activity Reports (SARs)?

Suspicious Activity Reports (SAR) must be reported to the FIU through an online form in goAML Web.

goAML is the FIU reporting tool - learn more about goAML.

For reporting entities already submitting online reports, completing a SAR online form will be similar to completing a Suspicious Transaction Report (STR).

Registering with the FIU and goAML (the FIU Reporting Tool)

If you are a new reporting entity not currently registered with the FIU you will need to register using the goAML Web application.

Information about how to register with the FIU is available in the "Registering in goAML" section on the goAML page.

When do I need to submit a Suspicious Activity Report (SAR)?

A SAR must be submitted to the FIU no later than three working days after reasonable grounds for suspicion are formed.

What information do I need to include in a Suspicious Activity Report (SAR)?

The grounds on which a reporting entity holds its suspicion must be clearly articulated within a SAR. Reporting entities must also identify any indicators of suspicious activity that they have identified.

Reporting entities will need to provide identification and contact information for their customer (as required by the AML/CFT Act). If an account or arrangement is involved – the type, number and information of the holder(s) must be provided.

Where a third party is involved, information that is already held by the reporting entity under the AML/CFT Act, and additional information that relates to the suspicious activity must also be provided.

Refer to Schedule 2 of the Anti-Money Laundering and Countering Financing of Terrorism (Requirements and Compliance) Act 2009 (reprint 28 September 207) for full details of the information that must be included in a SAR.

Resource Library: How to complete Suspicious Activity and Transactions Reports

Reference material on how to complete suspicious activities and transactions reports are available from the Resource Library in goAML.

The Resource Library is available for reporting entities who have registered with goAML.  To access, reporting entities will need to log into goAML and click on the question mark icon on the menu bar.