AML Client Risk Ratings
We Implement Your AML Client Risk Ratings and Ongoing Monitoring Framework
Is your business struggling with implementation of an AML Client Risk Ratings framework? AML360™ can quickly get you from non-compliant to compliant. Using Unique IDs so your business retains client confidentiality, our solutions automate individual Client Risk Rating Reports.
AML Risk Profiling
We develop your branded onboarding form to meet AML/CFT data requirements.
Ongoing Monitoring
Your customised onboarding form includes client risk profiling.
Compliance Reporting
Easily administer ongoing monitoring obligations with evidence-based solutions.
AML Client Risk Ratings & Ongoing Monitoring
From 1 June 2025, changes are happening for businesses that are captured under New Zealand’s compliance laws known as Anti-Money Laundering and Countering Financing of Terrorism (AML/CFT). By this date the business must have established and implemented a framework for AML client risk ratings.
New Zealand’s AML/CFT Supervisors are expecting businesses to demonstrate risk-based decision making when applying AML/CFT customer risk ratings.
Why Are AML Client Risk Ratings Important?
New Zealand’s Anti-Money Laundering compliance laws represent risk-based legislation. This means decision making relating to an AML/CFT Programme needs to be based on informed knowledge. AML/CFT Compliance Officers, Senior Managers and Board Members must have high-level understanding of AML/CFT compliance risks. This includes understanding inherent and real risk across the business client base.
Customer Risk Rating And Enhanced Due Diligence
In having informed knowledge of the AML customer risk rating, the business is able to demonstrate compliance for application of enhanced due diligence.
Enhanced Due Diligence (EDD) is a requirement under AML/CFT laws. Section 22(1)(d) of New Zealand’s Anti-Money Laundering and Countering Financing of Terrorism Act (AML/CFT Act), requires enhanced due diligence on higher risk customers.
If a business cannot demonstrate their decision making on higher risk customers, then they cannot demonstrate compliance with section 22(1)(d) for identifying clients of higher risk or Regulation 12AC for application of a risk rating.
Senior managers and Board members should receive some level of reporting on the business entity’s risk exposure to customer risk under AML/CFT laws.
Heat maps are a simple and effective method to inform at high levels. Heat maps should always be supported with a data report that explains the risk. These reports should be readily available to AML/CFT Compliance Officers, senior managers, Board members, auditors and AML/CFT Supervisors.
