Tell us a bit about your background, describe your current role and your responsibilities
Founder of two tech companies with 25 years experience solving business processing problems leveraging technology. CEO of Vigilance Ltd that has two best in class cloud solutions. One for protecting organisations from payment fraud and the other for Anti Money Laundry (AML) compliance. We see ourselves as digital crime fighters.
Note: We are rebranding our fraud protection product (VigilantPAY) and separating to a new website however this won’t be ready publication so better to avoid using old name for confusion.
What is the most rewarding part of your role?
Invitation and working with a great team to solve real customer problems.
What is your opinion on AML/CFT?
Aotearoa is not immune from organised crime, local or international so we need to protect NZ inc. While AML/CFT is seen as onerous from a compliance perspective the consequence of not having measures in place can impact any one of us.
What made you interested in AML and financial crime?
First hand experience drove me to protect others.
What is the most important thing you have learnt when it comes to AML?
AML/CFT is an ecosystem made up of many stakeholders that are interdependent and rely on each other to work effectively.
What are some of the biggest challenges in AML?
Identity theft, and maintaining effective compliance.
What would you consider the key thing people forget or do not understand when it comes to AML?
I’m not an auditor however often it’s the small things like not keeping an AML training register, or reviewing their compliance programme. If it isn’t documented then it didn’t happen, don’t wait until your audit to find you have a lot of retrospective work to do.
Do you think your sector adapted well to being under the AML/CFT Regime in New Zealand?
Quite well given the level of compliance needed.
How do you keep up to date with all things AML?
Same channels as reporting entities however we are in regular communications with a number key people in the industry. And we work closely with the DIA and FIU on projects.
What is the most rewarding part of working within your sector?
Making a real difference by improving and streamlining compliance processes.
What is your proudest achievement so far?
Vigilance being recognised as a market leader.
Do you have an interesting example or case study to share?
The invitation of criminals is always evolving - like two law firms litigating for their respective clients over a dispute, a settlement is reached, one pays the other a large sum of money. The lawyers are nun the wiser that they have just help launder money for the cost of their fees.
Payment fraud has been fueled by COVID, remote workforces and poor transparency and processes, invoice fraud and email compromises are at an all-time high. Protecting our digital borders is a far more complex problem than that of our physical borders.
What do you see the future of the AML industry being in New Zealand?
More compliance, more penalties being handed out, more reason for a solution providers like Vigilance.
Who in the AML world do you most admire?
Not sure there are any standouts but I do admire the attitude of most reporting entities who are getting on with it.
How well do you think the New Zealand AML regime stacks up against other jurisdictions?
Well we are ahead of the Ozzies. The Financial Action Task Force (FATF) recent review of NZ Inc’s AML/FCT stated we have a good understanding of AML/CFT but need improve the supervision of the private sector, it was recognised that it’s still relatively new for phase two reporting entities however my read on this is that the honeymoon is over.
Sam's Top 3 Tips
Don’t try to do it all yourself, reach out and ask for help. There are a lot of good people and knowledge out there.
Consider the whole picture not just CDD, think about an audit in 3 years from now, would that go well?
If you are under resourced or lack skills get help. The consequences of non compliance far outweighs the alternative.
Read more from experts in the AML industry with '5 minutes with an expert: Rosalind Lazar' who talks about her experiences in becoming CAMS Regional AML Director APAC ACAMS, or take a look at Withers Tsang's partner Nick Ashford's 'pathway to AML'