Agriculture equipment manufacturer AGCO worked with Execor to automate decarbonization cost curve building and planning efforts using the Catalyst Zero tool.
The Opportunity
Any accounting practice, either existing or established after the introduction of the AML/CFT Act, that conducts captured activities, will be a reporting entity and will have to comply with the Act. You will not be excused from compliance on the basis that to comply would breach any contract or agreement.29
Compliance requirements This section provides guidance on:
• The risk-based approach that reporting entities need to take when developing their AML/CFT programme
• The range of policies, procedures and controls reporting entities must include in their AML/ CFT programme to comply with the AML/CFT Act
• Things to consider if you wish to establish a designated business group to share some aspects of your AML/CFT programme and its implementation
Section 5 provides more detail about compliance requirements for CDD. Information on where to access other support to comply is noted in section 7.
Risk-based compliance The AML/CFT regulatory system in New Zealand is “risk-based”. This means your business must assess the risk it is exposed to from money launderers and terrorist financers. You must then apply suitable policies, procedures and controls to effectively manage the risks you have identified for your business. Compliance resources can then be targeted primarily at high-risk areas, which should reduce the overall compliance cost for your business. You are the best judge of the risks your business is exposed to and how you can most effectively mitigate those risks in line with the requirements of the AML/CFT Act. As your supervisor, DIA expects you to genuinely and accurately assess the ML/TF risks to your business and then apply a suitable and proportionate AML/CFT programme.
AML/CFT programme
– policies, procedures and controls AML/CFT compliance cannot be achieved with a “set and forget” approach. The AML/CFT programme needs to be fully implemented within the business. It should be a living and adaptable programme. Your specific compliance obligations under the AML/CFT Act are summarised below.
Appoint a compliance officer
You must appoint an AML/CFT compliance officer to administer and maintain your compliance programme.30 The compliance officer should be an employee of the business who reports to a senior manager or partner of the business. If practising on their own account, an accounting professional would be expected to act as the compliance officer themselves and take full responsibility for all compliance requirements unless there is a reason why they cannot. In that case they should appoint a third party to take on this duty.31
Conduct a risk assessment
All reporting entities must undertake a risk assessment, and it must be in writing. The specific requirements for a risk assessment are set out in section 58 of the AML/CFT Act.32 The supervisors have provided guidance on how to conduct a risk assessment.33 The AML/CFT Act requires that you have regard to guidance produced by the AML/CFT supervisors when developing your risk assessment.34 DIA has published its own assessment of the ML/TF risks in the sectors it is responsible for supervising, including in the accounting, bookkeeping and tax agency professions.35 DIA has also developed a “Prompts and Notes” guideline (AML/CFT Risk Assessment and Programme: Prompts and Notes for DIA Reporting Entities), which outlines the factors to be considered in a risk assessment along with some prompts for things to think about when completing a risk assessment and developing your AML/CFT programme.36 It provides prompts to help businesses undertake their risk assessment in a way that reflects both the size of their business and their level of risk
Record keeping
You must keep adequate records as outlined in sections 49 to 55 of the AML/CFT Act. This will enable you to operate your AML/CFT programme effectively and enable it to be audited by an independent auditor and reviewed by the supervisor on request. Records must either be kept in written form in English or be readily accessible and readily convertible into written form in English. You must keep your records for at least five years. The supervisor or the FIU may ask you to keep records for longer in some circumstances. After five years, the records must be destroyed unless there is a lawful reason why they should be retained, such as the need to comply with another enactment or to enable you to carry on your business.
“AGCO’s journey with Catalyst Zero is a testament to the power of innovative technology in driving sustainability and operational excellence.”
