PDF《Anti-Money Laundering》

2017 has drawn on aspects of New Zealand Police Financial Intelligence Unit (FIU) typology reports and from the existing SRAs of the FMA and the DIA. In addition, the SRA

2017 uses guidance and reports from other jurisdictions and international organisations such as the Financial Action Taskforce (FATF) which is the inter- governmental body developing and promoting policies to combat ML/TF. 6. The SRA

2017 works on two distinct levels. It provides an assessment of ML/TF risk and identifies key ML/TF vulnerabilities and how they impact each sub sector. A risk rating for ML/TF is not an indication of financial strength or stability of any financial sector or reporting entity within the sector. Assessment of risk 7. ML/TF risk is assessed as High, Medium or Low and is based on available data, guidance and appropriately experienced professional opinion. The table below summarises the assessed potential inherent ML/TF risk of each sub-sector as a whole and its constituent parts. Sub-sector Inherent risk of ML/TF Registered banks C overall inherent risk rating High Retail High Business/Commercial High Wholesale/Institutional Medium Non-Bank Deposit Takers C overall inherent risk rating Medium Deposit Taking Finance Companies Low Building Societies Medium Credit Unions Medium

5 5 | P a g e Life Insurers C overall inherent risk rating Low 8. The overall High risk rating for banks is consistent with the characteristics of the banking industry in the absence of AML/CFT controls. This is to be expected given the relative size of the banking sub-sector, the large number of customers and the high number and value of transactions compared to other areas. Combined with the wide availability and easy accessibility of products and services and access to international financial systems the banking sub-sector presents a much greater risk of ML/TF than the other sub-sectors. In this edition of the SRA, we have improved our assessment by providing a breakdown of retail banking, business/commercial banking and wholesale/institutional banking. However, the overall risk rating of High for the banking industry remains unchanged. 9. The overall Medium risk rating for the NBDT sector reflects the relatively smaller size and complexity of this sub-sector compared to the banking sub-sector even though it has some similar products and services to the retail banks. However, the NBDT sector is vulnerable to a number of ML/TF factors and may present an attractive avenue for ML/TF. In this edition of the SRA, we have reduced our assessment of overall ML/TF risk within the Deposit Taking Finance Companies, and have increased our assessment of overall ML/TF risk within the Credit Unions. However, the overall risk rating of Medium for the NBDT sector remains unchanged. 10. The overall Low risk rating for the insurance industry remains unchanged and reflects the smaller size and relatively simple life insurance products and services covered by the Act. While assessed as having a Low risk of ML/TF the insurance sector has a number of industry specific typologies and has been highlighted internationally as being potentially vulnerable to a number of ML/TF activities. Key vulnerabilities 11. The SRA

2017 identifies

12 key ML/TF potential vulnerabilities which impact reporting entities in all three of the RBNZ sub-sectors and are in line with domestic and international experience. The vulnerabilities presented in the table below are in no particular order as each sub-sector will prioritise vulnerabilities differently. Specific vulnerabilities should be fully considered in a reporting entity'