AML/CFT notes from AML Compliance Advisory Services
Reporting Entities obligations to report go beyond Prescribed Transactions (Large Cash, Occasional, Cross Border, etc). Phase II entities need to identify Typologies and behaviours that arouse suspicion and to report activity and transactions that are suspicious. The level of SAR/STR reporting from Phase II entities in NZ is extremely low, especially considering the number of entities involved. Time to stop complaining about the obligations and consider the big-picture advantages of compliance - improve your observation skills and start reporting. Happy to assist with any training.