More than $100 million in transactions may have not been properly checked under money-laundering laws by Qian DuoDuo Limited (QDD), which now faces a multi-million dollar government fine, a court has heard.

The Department of Internal Affairs (DIA) was seeking a fine of about $2.6 million, with Justice Grant Powell commenting that it was "truly extraordinary" that up to $7 million was at stake.

The department has accused QDD of failing to meet Anti-Money Laundering and Countering Financing of Terrorism Act (AML/CFT) requirements for customer due diligence, account monitoring, record keeping and risk assessment.

QDD, which was trading under Lidong Foreign Exchange, has not been accused of money laundering or funding terrorism.

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Today, Internal Affairs' lawyer David Johnstone suggested that QDD had used consultancy firm Starfish because of the questions posed to the business by DIA not because the company had been trying to keep up with its own compliance, a claim QDD director Ye (Cathay) Hua denied in the High Court at Auckland.

Trying to recall the details of an on-site inspection by DIA senior compliance officer, Robert Milnes, she broke down in tears.

"This is the Government charging me, I'm just a little woman doing business. How can I remember everything on that day?"

She said she forgotten the bad things in her life but remembered the good.

"If I remember every bad things of the past I will die. I will not live today."

Milnes had asked Hua for a six-monthly review of the relationship with money remitters and a record of the training provided to them.

Johnstone later asked Hua if she had lied about providing training to a company in December 2014, a claim she denied.

Hua had already confirmed she had "conducted a substantial volume of business with all of the six money remitters" throughout 2014.

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The first risk assessment with no mention of money remitters in March was out of date, Johnstone said.

"It was inaccurate."

Johnstone said not knowing what they should have been doing was not an excuse.

"But it calls for further condemnation from the court because that is just not good enough."

The DIA was seeking a starting point of a $2.6 million fine.

The department believed there should be a $2 million fine for failure in regards to risk assessment alone.

"If it's not $2 million then one wonders what it should be," Johnstone said.

An uplift in the penalty of 20 per cent was wanted for misleading the DIA, but a 20 per cent discount was offered for her admissions.

Hua's lawyer Mai Chen said Hua had gone to a consultant to ensure she was compliant.

"She did not intend to do any of these things," Chen said.

"That's not to say Ms Hua is not taking responsibility."

Chen said it stood far from the country's first case of its kind last year in which Ping An Finance (Group) was fined $5.3 million for multiple breaches of the AML/CFT Act.

"This is not a Ping An situation, we did not fail to turn up in court, we did not ignore every notice."

Chen said what QDD had done was wrong but it was "woeful not wilful".