The New Zealand Law Society has released information which gives practical guidance for use of its specimen AML/CFT compliance documents.
Lawyers are preparing for implementation of Phase 2 of the compliance regime prescribed by the Anti-Money Laundering and Countering Financing of Terrorism Act 2009.
The Law Society recently released a number of specimen compliance documents and templates which can be used to meet some compliance requirements.
Its intention is to provide a helpful starting point for understanding obligations under the Act and for development of internal policies and procedures to meet those obligations. The documents are not prescribed forms and will require adaptation.
The latest guidance released by the Law Society, How to use the New Zealand Law Society specimen compliance documents, notes that lawyers must adapt any AML/CFT specimen documents to take into account their particular circumstances.
"The intention is that the Law Society’s specimen AML/CFT compliance documents may provide a basic foundation upon which a tailored compliance framework can be built by law firms and sole practitioners," it says.
"That framework will need to reflect the practical realities, needs and unique aspects of each law firm and practice."