By Ivana Mlinac
Tell us a bit about your background, describe your current role and your responsibilities
I am currently a director at 2Compli Limited, an AML/CFT consultancy company I started with my business partner in 2017 providing auditing, training and development of AML/CFT Frameworks. Prior to this, I spent over 15 years in the banking industry as a Senior Manager in various areas, developing and optimising workflow processes.
What is the most rewarding part of your role?
The most rewarding part of my job is the development and facilitation of AML/CFT learning
programmes. I love to see the change in people from seeing compliance as something they have to do, to understanding the why and moving to how they can improve.
What is your opinion of the current AML/CFT regime within New Zealand? And, how does this compare internationally?
I think the risk-based approach works well for the Phase 2 reporting entities, although not all of them have understood how to identify risk and then rate it. I have found that using a coaching approach with clients developing a new AML/CFT Framework, or updating their existing Framework, helps them to identify risk and then own it with regards to procedures and policy.
What made you interested in AML/CFT and financial crime?
When Phase 2 was introduced, I felt I could use my considerable experience in the industry to assist reporting entities becoming compliant. I met Bernie Hankey through a mutual friend and we decided to work together and establish 2Compli. Two months later, I realised that Bernie Hankey was formerly Bernadine Naden, whom I used to go to school with in Gisborne. 35 odd years will do that.
What is the most important thing you have learned when it comes to AML/CFT?
We have worked with many different companies, and while there are similarities, we have realised that no two businesses are ever the same. Consequently, we do not take a template approach to auditing, training or developing AML/CFT frameworks for our clients - we identify each business' unique needs and provide solutions and tools to meet them.
What are some of the biggest challenges you have experienced in AML/CFT?
The biggest challenge, especially early on, was that many Phase 2 clients felt they knew all their customers. They felt they would never launder money and were therefore all low risk. As a result, we have had to carefully explain inherent and residual risk to almost all the reporting entities we have worked with.
What would you consider to be a key thing people forget or do not understand when it comes to AML/CFT?
The most common issue is that Phase 2 reporting entities find it difficult to determine when due diligence is required on third party referrers and third parties who complete due diligence on their behalf.
How do you tend to keep up to date with all things AML/CFT?
My business partner and I have a large network of people who work in this field and we jointly review communications from the sector supervisors and other compliance companies. We also attend the FIU conference each year, which has always been a great source of information and provides us with plenty of time to network.
Do you think your sector adapted well to being under the AML/CFT Regime in New Zealand?
Not particularly. There has been a huge amount of information from the sector supervisors, however this is stored in different places and in different formats.
While Phase 2 entities range from one-man bands to large multi-store businesses, the law's expectations remain much the same. I think further consideration of New Zealand's regulations is required, especially for smaller companies with limited resources. This is vital to ensure that businesses of all sizes are able to effectively follow AML/CFT regulations and maintain compliance in the long-run.
JOHN'S TOP TIPS
Understand the AML/CFT risks your business face.
Not only should these be formally reviewed at least twice a year, but so should your risk assessments as New Zealand is quickly and continually changing.
If you're ever feeling suspicious, report it.
If you feel unsure about whether or not to report it, always report as this keeps your reporting entity in safe harbour.
Always Invest in training.
Make the most of companies that provide training which meet your staff's specific needs, but be sure to measure how effective this has been.