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    Annual AML/CFT Report to the DIA

    Connectworks AML Reports can assist firms to complete their annual report to the DIA. 

    Below we have outlined how to obtain this information, in relation to the sections in the DIA User Guide: Annual AML/CFT Report by Designated Non-Financial Businesses and Professions March 2018 

    Quickly obtaining the relevant information information from Connectworks relies on the use of Microsoft Excel's filtering functionality. If you are unfamiliar with using filters in Excel we suggest reviewing this Microsoft support article before proceeding.

    Important
    The AML reports generated in Connectworks will only be accurate if you have:
    1.Loaded all your client profiles in Connectworks, and;
    2. Completed the AML workflow for all your clients, and;
    3. The profiles have been set up with the accurate & complete information saved in their Edit profile form. Eg. Companies have a record of the Registered Office address, Partnerships have the company type recorded as Partnership, or the trust type has been recorded as family, estate, charitable, etc.


    How to answer DIA Annual AML/CFT Questions using Connectworks

    Expand each section below for further details: 

    7.2 Do you act as, or arrange for a person to act as, a nominee director or nominee shareholder or trustee in relation to legal persons or legal arrangements?

    If you answered “yes”, estimate:

    • the number of nominee directorship roles your reporting entity holds.

    • the number of nominee shareholder roles your reporting entity holds.

    • the number of trustee roles your reporting entity holds.


    In Connectworks, your firm's Clients tab contains several reports which can help to calculate the number of these roles:


    Identify trustee roles:

    1. Navigate to your firms Clients>Trusts tab. 

    2. Select the "I would like to..." and download the Trustee report. Open the report in Excel.

    3. Turn on filtering for the headers in Row 1.

    4. In column AA "Trusteeship end date" filter to select the tick box for "Present" only (this will provide a list of active trusteeships).

    5. In column B "Name" filter to select the names of all your trustee companies.

    6. After applying the necessary filtering for the entity type, highlight all names that appear in Column D and in the bottom right corner of excel it will display the count number of the selected cells.


    Identify nominee directorship roles:

    1. Navigate to your firms Clients>Companies tab. 

    2. Select the "I would like to..." and download the People & Employees report. Open the report in Excel.

    3. Turn on filtering for the headers in Row 1.

    4. In column R "Directorship end date" filter to select the tick box for "Present" only (this will provide a list of active directorships).

    5. In column C "Name" filter to select the names of all your nominee directors.

    6. After applying the necessary filtering for the entity type, highlight all names that appear in Column C and in the bottom right corner of excel it will display the count number of the selected cells.

      NB. As Connectworks does not record a nominee directorship as a specific role, you will need to check your list to ensure other types of directorship are not included in this count.


    Identify nominee shareholder roles:

    1. Navigate to your firms Clients>Companies tab. 

    2. Select the "I would like to..." and download the People & Employees report. Open the report in Excel.

    3. Turn on filtering for the headers in Row 1.

    4. In column T "Shareholder" filter to select the tick box for "Current" only (this will provide a list of current shareholders).

    5. In column C "Name" filter to select the names of all your nominee shareholders.

    6. After applying the necessary filtering for the entity type, highlight all names that appear in Column C and in the bottom right corner of excel it will display the count number of the selected cells.

      NB. As Connectworks does not record a nominee shareholder as a specific role, you will need to check your list to ensure other types of shareholder are not included in this count.

    7.3 Do you provide a registered office or a business address, a correspondence address, or an administrative address for a company, or a partnership, or any other legal person or arrangement?* 

    If you answered “yes”, estimate the number of companies, partnerships, or other legal persons or arrangements that your reporting entity provides these services to. Select the estimated number.

    • Companies: 0; 1–10; 11–100; 101–999; 1000+

    • Trusts (excluding charitable trusts): 0; 1–10; 11–100; 101–999; 1000+

    • Partnerships (including limited partnerships): 0; 1–10; 11–100; 101–999; 1000+

    • Charities (including charitable trusts and other charitable entities): 0; 1–10; 11–100; 101–999; 1000+

    *Unless the office or address is provided solely as an ancillary service to the provision of other services.


    In Connectworks the volume of entities can be calculated precisely using the CDD Report. 

    There is a question in the CDD workflow which specifically addresses this scenario, which can be used as a filter. 

    However if CDD has not been completed for all your clients then you can also filter a list of these clients using the address filter instead. Both of these options are outlined below.

    If the AML Workflow/CDD has been completed for all clients:

    1. In the Work>AML tab select the "I would like to..." button and generate the CDD Report. Open the report in Excel.

    2. Turn on filtering for the headers in Row 1.

    3. Scroll across to Column AA - the header is "Providing a registered office or business address (other than as solely ancillary to a non-captured service)"

    4. Select the filter drop down and select the tick box for "Yes" only.

    5. In Column F "Client type" select the filter drop down and then select the tick box for type of entity from Company, Trust or Individual.

    6. Apply additional filtering if the entity is a:

      Company - in Column I "Type of Company" ensure "Partnership" is deselected.

      Partnership -  in Column I "Type of Company" ensure only "Partnership" is selected.

      Trust - in column J "Type of trust" ensure that "charitable" "estate" and any other non applicable trust types are deselected.

      Charitable Trust - in column J "Type of trust" ensure that only "charitable" is selected.

    7. After applying the necessary filtering for the entity type, highlight all names that appear in Column A and in the bottom right corner of excel it will display the count number of the selected cells.

    If the AML Workflow/CDD has NOT been completed for all clients:

    1. In the Work>AML tab select the "I would like to..." button and generate the CDD Report. Open the report in Excel.

    2. Turn on filtering for the headers in Row 1.

    3. Scroll across to Column K - the header is "Street 1" - this is the first line of the entities registered address and will appear even if CDD has not been completed for the client.

    4. Select the filter drop down and select the tick box for all instances of your firms address. You may need to select multiple variations.

    5. In Column F "Client type" select the filter drop down and then select the tick box for type of entity from Company, Trust or Individual.

    6. Apply additional filtering if the entity is a:

      Company - in Column I "Type of Company" ensure "Partnership" is deselected.

      Partnership -  in Column I "Type of Company" ensure only "Partnership" is selected.

      Trust - in column J "Type of trust" ensure that "charitable" "estate" and any other non applicable trust types are deselected.

      Charitable Trust - in column J "Type of trust" ensure that only "charitable" is selected.

    7. After applying the necessary filtering for the entity type, highlight all names that appear in Column A and in the bottom right corner of excel it will display the count number of the selected cells.

    7.4 Do you manage client funds (other than sums paid as fees for professional services), accounts, securities, or other assets?

    If you answered “yes”, estimate the value of funds managed in the last year. Select the estimated value. 
    0; $1–999,999;
    $1,000,000– $9,999,999;
    $10,000,000– $49,999,999;
    $50,000,000 and over


    In Connectworks you can easily identify if such services have been provided by your firm.


    1. In the Work>AML tab select the "I would like to..." button and generate the CDD Report. Open the report in Excel.

    2. Turn on filtering for the headers in Row 1.

    3. In column AB " Managing client funds (other than sums paid as fees for professional services), accounts, securities, or other assets" apply a "Yes" filter.
      If any results appear then the answer to this question will be yes.

      The clients showing under this filtering should then be further investigated to obtain the financial information relating to the second part of this question.

    7.5 Do you provide real estate agency work (within the meaning of section 4(1) of the Real Estate Agents Act 2008) to effect a transaction (within the meaning of section 4(1) of that Act)? 


    In Connectworks you can easily identify if such services have been provided by your firm


    1. In the Work>AML tab select the "I would like to..." button and generate the CDD Report. Open the report in Excel.

    2. Turn on filtering for the headers in Row 1.

    3. In column AC "Providing real estate agency work to effect a transaction" apply a "Yes" filter. If any results appear then the answer to this question will be yes.

    7.6 Specify which of the following services you engage in or give instructions on behalf of a customer to another person for:

    a. any conveyancing (within the meaning of section 6 of the Lawyers and Conveyancers Act 2006) to effect a transaction (within the meaning of section 4(1) of the Real Estate Agents Act 2008, and as specified in paragraph (a)(vi)(A) of the definition of “designated non-financial business or profession” in section 5(1) of the Act); 

    b. a transaction within the meaning of section 4(1) of the Real Estate Agents Act 2008; 

    c. the transfer of a beneficial interest in land or other real property; 

    d. a transaction on behalf of any person in relation to the buying, transferring, or selling of a business or legal person (for example, a company) or any other legal arrangement; 

    e. a transaction on behalf of a customer in relation to creating, operating, and managing a legal person (for example, a company) or any other legal arrangement.


    In Connectworks this information is gathered as part of the AML/CDD Workflow. If the AML Workflow has been completed for all Clients then the CDD report can be generated to check which clients your firm has conducted these 
    services for. 

    To review these details:

    1. In the Work>AML tab select the "I would like to..." button and generate the CDD Report. Open the report in Excel.

    2. Turn on filtering for the headers in Row 1.

    3. The answers to this question are split across multiple columns with the following headers:

      Column AD: Engaging in or giving instructions on behalf of a customer to another person for any conveyancing to effect the sale, the purchase, or any other disposal or acquisition of a freehold estate or interest in land.

      Column AE: Engaging in or giving instructions on behalf of a customer to another person for any conveyancing to effect the grant, sale, or purchase or any other disposal or acquisition of a leasehold estate or interest in land (other than a tenancy).

      Column AF: Engaging in or giving instructions on behalf of a customer to another person for any conveyancing to effect the grant, sale, or purchase or any other disposal or acquisition of a licence that is registrable under the Land Transfer Act 1952v.

      Column AG: Engaging in or giving instructions on behalf of a customer to another person for any conveyancing to effect the grant, sale, or purchase or any other disposal or acquisition of an occupation right agreement within the meaning of section 5 of the Retirement Villages Act 2003.

      Column AH:  Engaging in or giving instructions on behalf of a customer to another person for a transaction (within the meaning of section 4(1) of the Real Estate Agents Act 2008).

      Column AI: Engaging in or giving instructions on behalf of a customer to another person for the transfer of a beneficial interest in land or other real property.

      Column AJ: Engaging in or giving instructions on behalf of a customer to another person for a transaction on behalf of any person in relation to the buying, transferring, or selling of a business or legal person and any other legal arrangement.

      Column AK: Engaging in or giving instructions on behalf of a customer to another person for a transaction on behalf of a customer in relation to creating, operating, and managing a legal person and any other legal arrangement.

    4. If any results appear when filtering for "Yes" in each of these columns, then the answer to this question will be yes.

      The clients showing under each of these filters should then be further investigated to obtain the financial information relating to the second part of this question.

    8.1 Estimate how many customers you conducted CDD on this year in the course of carrying out activities regulated by the Act:

    Customer due diligence (CDD) is about knowing your customer and verifying their identity. It is also the process through which you develop an understanding of your customers, the kind of activities you can expect them to undertake through your business, and the ML/TF risks they pose to your business. This relates to the customers to whom you have provided services that include the activities that are captured by the Act. Refer to the guidance36 for your sector for further information on CDD. If you have not on-boarded any new customers, then the answer may be zero. You should state why this is the case.


    In Connectworks you can calculate the number of clients your firm has performed client due diligence on precisely using the Identity Verification Report


    • In the Work>AML tab select the "I would like to..." button and generate the Identity Verification Report. Open the report in Excel.

    • Turn on filtering for the headers in Row 1.

    • In column AW "Determination Date" select the filtering function "between" and then select the applicable date range.

    • After applying the necessary filtering, highlight all names that appear in column A and in the bottom right corner of excel it will display the count number of the selected cells. This will be the your answer.

    8.2 Estimate how many of the customers referred to in question 8.1 above are:

    1. classified as politically exposed persons (PEPs) (include your customers that are beneficially owned or are controlled by, or for the benefit of, a PEP)

    2. a trust or another vehicle for holding personal assets

    3. an overseas government body

    4. a New Zealand resident individual

    5. a New Zealand resident entity (including companies, partnerships, trusts, charities, and other incorporated or unincorporated entities)

    6. a non-resident individual

    7. a non-resident entity (including companies, partnerships, trusts, charities, and incorporated societies)


    In Connectworks, the answer to this question is contained in the Identity Information Report. How to review the information for each is detailed below:


    1. Politically Exposed Persons

    • In the Work>AML tab select the "I would like to..." button and generate the Identity Verification Report. Open the report in Excel.

    • Turn on filtering for the headers in Row 1.

    • In column AW "Determination Date" select the filtering function "between" and then select the applicable date range.

    • Filter Column AT for "Is exposed"

    • After applying the necessary filtering, highlight all names that appear in column A and in the bottom right corner of excel it will display the count number of the selected cells. Make a note of this figure.


    2. A trust or another vehicle for holding personal assets 

    • In the Work>AML tab select the "I would like to..." button and generate the CDD Report. Open the report in Excel.

    • Turn on filtering for the headers in Row 1.

    • In column F filter by client type "trust"

    • In column J "type of trust" select all applicable trust types holding personal assets, eg. Family, Investment, Property, Estate

    • In column R "Determination Date" select the filtering function "between" and then select the applicable date range.

    • After applying the necessary filtering, highlight all names that appear in column A and in the bottom right corner of excel it will display the count number of the selected cells. Make a note of this figure.



    3. an overseas government body

    This detail is not available from Connectworks reports.



    4. a New Zealand resident individual

    • In the Work>AML tab select the "I would like to..." button and generate the Identity Verification Report. Open the report in Excel.

    • Turn on filtering for the headers in Row 1.

    • In column F filter by client type "person"

    • In column Q "Country of residence" filter by "New Zealand"

    • In column AW "Determination Date" select the filtering function "between" and then select the applicable date range.

    • After applying the necessary filtering, highlight all names that appear in column A and in the bottom right corner of excel it will display the count number of the selected cells. Make a note of this figure.



    5. a New Zealand resident entity 
    (including companies, partnerships, trusts, charities, and other incorporated or unincorporated entities)

    • In the Work>AML tab select the "I would like to..." button and generate the CDD Report. Open the report in Excel.

    • Turn on filtering for the headers in Row 1.

    • In column F filter by client type "company" and "trust"

    • In column O "Country" filter by "New Zealand"

    • In column R "Determination Date" select the filtering function "between" and then select the applicable date range.

    • After applying the necessary filtering, highlight all names that appear in column A and in the bottom right corner of excel it will display the count number of the selected cells. Make a note of this figure.


    6. a non-resident individual

    • In the Work>AML tab select the "I would like to..." button and generate the Identity Verification Report. Open the report in Excel.

    • Turn on filtering for the headers in Row 1.

    • In column F filter by client type "person"

    • In column Q "Country of residence" filter by everything except "New Zealand"

    • In column AW "Determination Date" select the filtering function "between" and then select the applicable date range.

    • After applying the necessary filtering, highlight all names that appear in column A and in the bottom right corner of excel it will display the count number of the selected cells. Make a note of this figure.


    7. a non-resident entity 
    (including companies, partnerships, trusts, charities, and incorporated societies)


    • In the Work>AML tab select the "I would like to..." button and generate the CDD Report. Open the report in Excel.

    • Turn on filtering for the headers in Row 1.

    • In column F filter by client type "company" and "trust"

    • In column O "Country" filter by everything except "New Zealand"

    • In column R "Determination Date" select the filtering function "between" and then select the applicable date range.

    • After applying the necessary filtering, highlight all names that appear in column A and in the bottom right corner of excel it will display the count number of the selected cells. Make a note of this figure.


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