Prescribed Transactions Reporting

Changes to the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT Act) and regulations introduced new requirements for reporting entities to report prescribed transactions in the form of Large Cash Transaction (LCT) reports and International Fund Transfer (IFT) reports.

Reporting entities have been introduced as part of the Anti-Money Laundering and Countering Financing of Terrorism Amendment Act 2017. Please refer to the Ministry of Justice website for further information.

Why Was This Legislation Introduced?

Prescribed Transactions Reports (PTRs) help to build an intelligence picture across the entire financial system, providing necessary statistics and useful intelligence on the flow of cash and money in and out of New Zealand.

In addition to Suspicious Activity Reports (SARs), PTRs add further transparency to the financial system by making certain money laundering and terrorist financing typologies even more difficult to hide, as well as improving the detection, and thus disruption, of organised crime, fraud and tax evasion.

What is a Prescribed Transaction?

Prescribed Transactions are transactions conducted through a reporting entity in respect of:

International Funds Transfers (IFTs) – an international wire transfer of NZD$1,000 or more where at least one of the institutions involved in the transaction (i.e. ordering, intermediary or beneficiary institution) is in New Zealand, and at least one is outside of New Zealand.

Large Cash Transactions (LCTs) – a domestic, physical cash transaction of NZD$10,000 or more involving physical currency (i.e. coin and printed money designated as legal tender).

 

Five steps to prepare for submitting Prescribed Transaction Reports

 

The five steps below have been developed as a guide to assist reporting entities prepare for submitting Prescribed Transactions Reports.

five steps to submitting PTR flowchart

 

Step 1 – Prepare the information

Determine what information needs to be provided

The information that needs to be included in PTRs (IFTs and LCTs) is outlined in the relevant legislation, regulations, and guidance documents. These are available from the 'Legislation and Guidance Documents' section below.

Additional testing guidance, including technical documents, is available in the Resource Library within goAML. To access the Resource Library, registered reporting entities will need to log in to goAML and click the question mark (?) icon on the menu bar.

Ensure that you capture the required information

If you don’t already, you will need to develop a way (either manually or automated) to start collecting the required information in order to meet your obligations.

You will need to determine where the information is, and in how many different places (systems, databases etc.).

For example:

FIU capture information flowchart

Determine how easy/difficult it will be to bring all the information together

If the information is in many different places and formats/structures, determining how easy (or difficult) it will be to bring all of the information together will help you to identify the best way for your entity to submit PTRs.

Estimate the volume and frequency of transactions

Having an idea of how many Large Cash Transactions (LCTs) and International Funds Transfers (IFTs) your entity will need to submit, and how often you will need to submit reports, will also help you to identify the best way for your entity to submit PTRs.

 

Step 2 – Decide how to submit

The information you have prepared in Step 1 will assist with identifying which of the following options is best for your entity to submit PTRs:

  1. Manual entry using the online goAML web forms
  2. XML file upload via goAML web
  3. Business-to-business (B2B) fully automated submission

All three methods require the same information to be provided.

Further information about the three different methods is available from the ‘How to submit PTRs’ section, including some criteria for developing an automated solution (options 2 and 3).

Keep in mind the cost of developing or purchasing automated reporting systems, vs the volume and frequency of transactions that require reporting. 

 

Step 3 – Develop your system

After you have worked through Steps 1 and 2, specific documentation is available to assist reporting entities with submitting PTRs – appropriate for each submission method.

If your reporting entity is already registered for goAML, PTR documentation is available from the Resource Library within goAML. To access the Resource Library, registered reporting entities will need to log in to goAML and click the question mark (?) icon on the menu bar.

If you are not yet registered for goAML, refer to the ‘Registering in goAML’ section of the ‘goAML – Financial Intelligence Unit Reporting Tool’ page.

Please note: Further updates to guidance documents will be released when required – either as a result of legislative changes, or a goAML upgrade (provided by the software solution provider).

 

Step 4 – Test your system

Each reporting entity that will be submitting PTRs via an automated method (options 2 or 3) must successfully complete a testing process with the FIU before access to submit automated reports in the production environment is approved in writing.

Further information about the testing process is available from the ‘Testing Prescribed Transaction Reports’ section below.

 

Step 5 – Prepare your people

Specific documentation has been prepared to assist reporting entities and their people for submitting PTRs via each method. All documentation is available from the Resource Library in goAML. To access the Resource Library, registered reporting entities will need to log in to goAML and click the question mark (?) icon on the menu bar.

 

Manual entry using the goAML online web forms

Reference guides are available to help reporting entities complete the online web forms for Large Cash Transactions (LCTs) and International Funds Transfers (IFTs).

Hands-on training for manual entry using the online web forms is available to reporting entities. To register your interest, please email goAMLTraining@police.govt.nz

XML file upload via goAML web and Business-to-business (B2B) fully automated submission

No documentation is provided for these options in regards to preparing your people, as it is a automated solution and requires little to no user intervention.

 

How to submit Prescribed Transaction Reports

Submission Methods

There are three methods available for submission of PTRs to the FIU:

  1. Manual entry using the online goAML web forms
  2. XML file upload via goAML web
  3. Business-to-business (B2B) fully automated submission

Option 1 requires no technical development by a reporting entity.

Options 2 and 3 are automated methods which will require technical development from a reporting entity, or a third party software solution provider.

five steps to submitting PTR flowchart

 

Option 1 – Manual entry using the online goAML web forms

This option requires a user to log in to the goAML web portal and complete an online form (similar to the Suspicious Activity Report and Suspicious Transaction Report forms).

No technical development is required by a reporting entity, however staff will need to be trained on how to use and correctly fill out the web forms. Training on how to manually complete forms is available. To register your interest please email: goAMLTraining@police.govt.nz

 

Option 2 – XML file upload via goAML web

This option requires a reporting entity to develop a solution that may link multiple databases together, depending on where the required information is held. A user then needs to manually upload a valid XML file (or ZIP file containing multiple XML files) relating to multiple transactions.

Please note: International Funds Transfers (IFTs) and Large Cash Transactions (LCTs) must be contained in separate files – i.e. one XML file can contain multiple IFTs, but not a combination of IFTs and LCTs).

This option may be beneficial for a reporting entity if they expect higher volumes of transactions, and/or already has systems in place that successfully integrate the required information for PTRs.

 

Option 3 – Business-to-business (B2B) fully automated submission

This option enables a reporting entity to send PTRs automatically (most likely on a daily basis) to the FIU.

Like option 2, it requires initial investment by a reporting entity in developing a solution that links multiple databases together, depending on where the required information is held.

Once the B2B solution is successfully in place, no manual user intervention is required, however a monitoring process will need to be implemented to ensure that reports are successfully processed.

 

Criteria for automated submission (XML upload or B2B)

To develop an automated PTR solution, reporting entities should carefully consider whether:

  • The required information is currently captured by business processes and systems, and where and how the information is stored.

    If the information is captured manually or in paper form, it will be difficult to generate an XML file.
     

  • Your reporting entity has the appropriate technical expertise and resources to prepare and maintain the solution (both technical and business/compliance).

    Developing an automated solution requires specialised technical expertise. If reporting entities do not have (or have access to) IT expertise, developing an automated solution will be challenging.

    Reporting entities may wish to consider engaging with a third party software solution provider to develop an automated solution for submitting PTRs to the FIU.
     

  • There is appropriate budget available for preparing and maintaining a technical solution.

    Automated submission of PTRs to the FIU requires investment in technology and resources to prepare, maintain, and upgrade the automated solution. Alternatively, a third party software solution provider may be a viable option for your reporting entity. Automated solutions, whether developed in house or created by a third party software provider, are a continuous investment due to changes in software, legislation, regulations, and data access/quality.
     

  • The anticipated volume of transactions that will need to be reported justifies investment in an automated solution.

    Developing an automated solution for the submission of PTRs to the FIU allows reporting entities to submit many transactions at one time. If a reporting entity does not expect to be submitting high volumes of transactions, there may not be benefit in investing in an automated solution.

 

Testing Prescribed Transaction Reports

 

Reporting entities that intend to submit PTRs via an automated method (XML upload or B2B submission) must successfully complete a testing process with the FIU before access to submit automated reports in the production environment is approved in writing.

For further information about the testing process, refer to the Test Guide document available from the Resource Library within goAML. To access the Resource Library, registered reporting entities will need to log in to goAML and click the question mark (?) icon on the menu bar.

 

Preparing to test

Before beginning to test reports in the New Zealand Police goAML testing environment, we recommend that reporting entities test sample files internally first.

We also recommend that reporting entities complete a report manually by filling in the online web forms in the testing environment, then download the XML after it has been successfully processed. This will allow reporting entities to view a schema compliant XML file. Alternatively XML example files can be requested by registered reporting entities by emailing: goamlconsult@police.govt.nz

 

Testing automated reports

There are three key stages of the testing process for automated submission of PTRs:

  1. Successful connection to the NZ Police testing environment;
  2. Successful validation (at the Schema level) of files; and
  3. Completion of multiple manual file reviews with the FIU.

test automated reports flowchart

 

Testing in the NZ Police testing environment

Reporting entities should test files and transactions that cover all scenarios they are required to report (as per legislation and regulations).

Some scenarios you may want to test include:

  • Inward international funds transfers
  • Outward international funds transfers
  • Large cash deposits
  • Large cash withdrawals
  • Currency exchanges

We recommend that reporting entities use this testing phase as an opportunity to develop and write processes and procedures to support the submission of PTRs in the production environment.

IMPORTANT NOTE: Real data that can identify an individual, entity or account MUST NOT be submitted in the testing environment. Test data should be representative of real data, but appropriately obfuscated so that it is not identifiable (e.g. change the client’s name to ‘Jane Doe’ and the account to ‘123456789’ rather than ‘dsjlkajhdsgf’ and ‘0000’).

Manual file review

Once a number of files have been successfully validated against the schema in the testing environment, reporting entities need to complete the PTR File Review Template (contained within the Test Guide document) and email it to goamlconsult@police.govt.nz.

The purpose of the review is to assist the FIU in understanding the context behind transactions that represent those that will eventually be submitted to the production system. The review also allows the FIU to identify any areas where mandatory information (as required by the legislation) may be missing. After feedback is provided on the first file review, the reporting entity will need to submit further file reviews until the FIU are confident in the quality, accuracy, and compliance of the test reports. Once testing is complete, the FIU will notify the reporting entity, by email, that they are approved to start submitting automated reports in the production environment.

Please note: Successful completion of the file review process does not confirm regulatory and legislative compliance.

 

 

Legislation and Guidance Documents

AML/CFT Act and PTR Guidance

 

Relevant acts and regulations are available from the NZ Legislation website, and include:

Guidance documents produced by the FIU include:

Additional guidance documents are available for reporting entities from the Resource Library within goAML. To access the Resource Library, registered users of goAML will need to login and click on the question mark (?) icon from the task bar.

 

 

Need More Information?

Other Resources

 

Not sure if you need to submit PTRs? Refer to your sector supervisor.

 

Still need more information?

Questions and answers in this document have been collaboratively determined by the FIU, Ministry of Justice and the three Sector Supervisors (DIA, FMA and RBNZ).

If you are still unable to find an answer to your question, please email us.