AML/CFT Auditing during the COVID-19 pandemic

The Department of Internal Affairs has said that it is preparing to respond to sector concerns regarding the ability to meet some AML/CFT Act obligations as a result of the COVID-19 pandemic. “Two areas of immediate concern relate to businesses’ ability to complete their independent audit and submit their annual report by 31 August 2020.”  

Many New Zealand law firms are now subject to the AML/CFT Act. Those law firms are required to engage an independent auditor to complete a statutory audit of their AML/CFT programme by 30 June 2020. 

It may be that the DIA extends the time period. We should know more about this in the days ahead. However, depending on your current workflows, now might be the perfect time to commence your audit process.  

We are able to start your audit notwithstanding the lockdown. We can still review your risk assessment, the compliance programme, any related documents such as file/matter opening forms, any registers you may have (such as the training register, PEP register, exceptions to IVCOP), training materials (if any) and evidence of vetting (if any). We will need to look at new ways of reviewing files and conducting interviews but we can discuss the logistics once the written documents have been reviewed. 

If you are yet to appoint your auditor for the current audit cycle, or you would like to discuss the process, please get in touch with us. 

Neil Russ 

Alexandra Tunnicliffe 

Charlotte Beale

Tracy Owen