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Introduction to Anti-Money Laundering





Money laundering means taking dirty money and making it look clean. Dirty money is the proceeds of crime. In the money laundering cycle, the dirty money is first placed into the financial system, then the dirt is concealed by transactions and tricks, then the money is withdrawn looking clean.


Below is the New Zealand Police information about their Financial Crime Group, which tackles money laundering and related issues. That text is here on the Police website, together with links to further information.


We have earlier discussed money laundering and related issues in employment law:

Convicted Money Launderer and Future Employment Advocate? 21 Nov 2020

How to Gag a Whistleblower in the NZ Public Service 12 Oct 2020

No Police, No WorkSafe, No Media. Or Else. 21 June 2020

Well Worth The Money! 21 May 2020


Leighton Associates also recommends the 2019 film "Laundromat". This stars Meryl Streep and is on Netflix. It is about the law firm Mossack Fonseca, which was based in Panama but also operated in New Zealand between 2013 and 2017, when it was shut down after the "Panama Papers" scandal.


Financial Crime Group (FCG)

The Financial Crime Group (FCG) is made up of the Financial Intelligence Unit (FIU), based at Police National Headquarters, the Money Laundering Team (MLT) based in Auckland and the Asset Recovery Units (ARUs), which are located in Whangärei, Auckland, Hamilton, Tauranga, Wellington and Christchurch.


The core functions of the FCG include:

  • receiving, analysing and disseminating financial intelligence

  • undertaking the restraint and forfeiture of criminally acquired or derived assets for all government law enforcement agencies

  • investigating money laundering syndicates and professional money laundering facilitators.

Financial Intelligence Unit (FIU)

The Financial Intelligence Unit (FIU) is mandated to assist with the detection and investigation of money laundering, terrorism financing and other serious offences.

It collects, analyses and disseminates financial information received under the Anti Money Laundering and Countering Financing of Terrorism Act 2009. These functions are undertaken on behalf of the Commissioner of Police to assist all government agencies that have a law enforcement role, financial sector supervisors or other domestic and international partner agencies.

The FIU:

  • generates a range of intelligence products, including proactive and targeted financial offender profiles;

  • provides advice on policy and legal matters where appropriate;

  • produces the National Risk Assessment (NRA);

  • provides guidance material on money laundering and terrorism financing and;

  • conducts outreach and training to New Zealand Police workgroups, partner agencies and AML/CFT reporting entities, including an annual conference seminar.

Asset Recovery Units (ARUs)


The Asset Recovery Units (ARU’s) were established in December 2009, specifically to implement the Criminal Proceeds (Recovery) Act 2009 (CPRA).

The intention of CPRA is to disrupt, deter, and derail crime with an emphasis (but not limited to) on the areas of organised crime and methamphetamine offending. This is achieved by denying criminals the opportunity to either enjoy the benefits of offending or to reinvest those proceeds in further criminal activity.

Cases are investigated using complex forensic accountancy and financial analysis processes, which are undertaken as part of an all-of-government approach that includes other agencies such as Customs, the Serious Fraud Office (SFO), and Inland Revenue. The ARUs also collaborate with overseas law enforcement agencies and provide advice on matters in relation to proceeds of crime policy and legislation.

The Money Laundering Team (MLT)


The Money Laundering Team (MLT) was established in 2017 to bridge the investigative gap between financial intelligence, financial investigations and organised crime investigations.

The MLT investigate criminal offenders moving the proceeds of predicate offending. The focus is on disrupting and dismantling facilitators assisting organised criminal groups to hide illicit funds, including legal professionals and other third parties such as money remitters.

The team has two points of focus:

  1. Proactively investigating syndicates and the persons supplying them with criminal proceeds, working closely with all of our government partners including Department of Internal Affairs (DIA), Customs, Financial Markets Authority (FMA) and the Reserve Bank to bring criminal or regulatory charges where they are required.

  2. Providing support and general advice to Police Districts, National Organised Crime Group (NOCG) and external partners by way of investigative enquiries and support, transaction analysis, account analysis and charging advice.

Forensic accounting support and financial analysis expertise is often provided where required to support charges that are deemed appropriate, with formal statements completed and oral evidence given during court hearings.


Financial Crime Prevention Network (FCPN)


The Crime Prevention Network (FCPN) is New Zealand’s Public Private Partnership which is chaired by the Financial Crime Group and includes members from NZ Customs, ANZ, ASB, BNZ, Kiwibank, and Westpac.

A work plan has commenced to produce four joint strategic typology products which will cover the topics of child exploitation, trade based money laundering, virtual asset service providers, and trust and company service providers.


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