While the terrorism threat that New Zealand itself faces is rated as 'low' by the international community, the FIU notes it is still exposed to threats relating to terrorism financing overseas, including the potential for financiers of overseas groups within New Zealand, and overseas-based groups which may seek to use the country as a conduit for funds.
"Given the global nature of TF and the constantly changing nature of international tensions and conflicts, the risks associated with TF are highly dynamic. As such, reporting entities need to ensure that their CFT measures are current, regularly reviewed and effective," the RBNZ report said.
According to the RBNZ, the high potential risk in the banking sector is due to its relative size, the large number of customers and the high number and value of transactions compared to other areas. Combined with the wide availability and easy accessibility of products and services and access to international financial systems the banking subsector presents a much greater risk of ML/TF than the other subsectors, it said. "The value, volume and velocity of banking transactions provide an environment which conceals, disguises or obfuscates the proceeds of crime," it said.
Within the sector, retail banking and business/commercial banking are rated high risk while wholesale/institutional banking is rated medium.
The non-bank deposit takers are rated medium, reflecting the "relatively smaller size and complexity of this subsector compared to the banking subsector even though it has some similar products and services to the retail banks." It did note, however, the sector is vulnerable to a number of ML/TF factors and may present an attractive avenue for ML/TF.
The overall 'Low' risk rating for the insurance industry remains unchanged and reflects the smaller size and relatively simple life insurance products and services.
The assessment identified 12 key potential vulnerabilities that cut across all three subsectors including trusts and shell companies, as New Zealand's open business environment and common use of trusts is highly vulnerable to ML/TF abuse, it said. "All shell companies and trusts, including family trusts, should be considered highly vulnerable to ML/TF activity," according to the RBNZ.
Other potential weaknesses include new payment technology as it may create vulnerabilities that emerge faster than ML/TF controls can respond. "ML/TF via internet and online banking presents a quick and easy anonymous, cross-border channel which moves funds faster than enforcement can keep up with. This vulnerability also includes Alternative Banking Platforms and ecurrencies," it said.
The RBNZ currently supervises 110 reporting entities including 24 registered banks, 14 life insurance providers, 27 NBDTs and 45 reporting entities who are the members of a designated business group