An interview with Carolyn Cody, Manager of Training Liaison and Compliance with the Financial Intelligence Unit.
By Ivana Mlinac
Tell us a bit about your background, describe your current role and your responsibilities
I am currently the Manager of Training Liaison and Compliance with the Financial Intelligence Unit (FIU). I have been with the FIU for almost 7 years. Prior to this I spent 10 years in the banking industry as an Investigations Manager dealing with both internal and external fraud related matters and prior to that 20 years as a sworn member of the New Zealand Police, 13 of those as a Detective. My current team of 6 looks after:
The registration of new reporting entities and users
The receiving of all reports that reporting entities must submit under legislation
Validating the content of those reports
Compliance with the legislation
Training to reporting entities – includes face to face, e-learning and guidance documents, and;
presentations to the wider AML/CFT audience.
What is the most rewarding part of your role?
For me the opportunity to deliver training and presentations to those involved in AML/CFT enables me to stress the importance from a national perspective, why certain industries were brought in under Phase 2 and demonstrate the positive impact reporting has on the disruption of organised crime and money laundering.
What is your opinion of the current AML/CFT regime within New Zealand? And, how does this compare internationally?
The AML/CFT regime in New Zealand is very strong and for the most part is very effective. Internationally, I believe we do well with reporting and generally have a good understanding of its importance, in order to make New Zealand the safest country.
What made you interested in AML/CFT and financial crime?
My time as a Detective in the NZ Police saw me spend many years on Fraud Squad and as such I learnt the value of “following the money”. It also showed the damage that is done within our community from the many crimes committed. Basically the bottom line is, criminals commit crimes for financial gain. Take away the money and it hurts.
What is the most important thing you have learned when it comes to AML/CFT?
That, with the many aspects of criminal offending, we need all pieces of the jigsaw puzzle to give the full picture so law enforcement can maximise their impact. Every reporting entity needs to do their bit and they should never think “my piece of information isn’t important.”
What are some of the biggest challenges you have experienced in AML/CFT?
Technology. Terminology. Legislative terms do not always reflect the language used in the AML/CFT reporting tool, goAML. Not every situation fits nicely into goAML. For this reason we have a selection of learning tools available in the Resource Library in goAML that registered users can access once logged in. Used in conjunction or stand alone, they are designed to assist reporting entities when a problem occurs. If the problem isn’t resolved through the guidance, then we have the Message Board for an enquiry to be sent through to my team. This is ‘manned' by the entire team so a response is pretty quick.
What would you consider to be a key thing people forget or do not understand when it comes to AML/CFT?
There is a small number of people who we deal with that are of the opinion that reporting is a punitive measure rather than a legislative requirement. It can be challenging for a person with a fixed mind-set to actually realise the huge value they hold in the regime. This can be due to a lack of knowledge or simply that someone hasn’t explained their worth to them.
Having said that, information we have received has added value to a number of investigations and in some cases, instigated an investigation.
Carolyn's Top Tips
KNOW YOUR CUSTOMER AND KNOW THEIR BUSINESS
This will protect you from inadvertently being taken advantage of by some savvy criminals looking to abuse the service you provide.
NEVER THINK YOUR INFORMATION IS TOO SMALL TO MAKE A DIFFERENCE
Report what you deem to be suspicious in the case of STRs and SARs.
OPEN YOUR MINDS TO THE BIG PICTURE
If you keep a closed mind strictly on your industry, you may miss something sitting on the periphery that is very important.