All steps in the module have been updated:

• [CO1] Step 1. Understanding what the law requires and what best practice suggests
• [CO2] Step 2. Selecting the AMLCO — role dimensions and the skill set required
• [CO3] Step 3. Selecting the AMLCO — eligibility and suitability/capacity
• [CO4] Step 4. Selecting the AMLCO — other possibilities
• [CO5] Step 5. Understand the full scope of the AMLCO’s responsibilities and role
• [CO6] Step 6. Vetting/training the AMLCO, and getting them up and running
• [CO7] Step 7. Reporting to senior management, and governance within the firm
• [CO8] Step 8. Support from senior management, accountability and liability
• [CO9] Step 9. A note to the AMLCO

Among other things, the update refers to the following insofar as they relate to AMLCOs:

• The 2021–2022 statutory review of the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 by the Ministry of Justice (see MOJ “We want to hear what you think about our Anti-Money Laundering Laws” <www.justice.govt.nz>).
• Financial Markets Authority v CSLA Premium New Zealand Ltd [2021] NZHC 2325.
• The formal warning given to a law firm in 2021 by the Department of Internal Affairs (see DIA “Internal Affairs issues a formal warning to Kidd Legal for Anti-Money Laundering non-compliance” (press release, 17 March 2021) <www.dia.govt.nz>).
• Department of Internal Affairs v OTT Trading Group Ltd [2020] NZHC 1005.

For further information, see Gary Hughes Anti-Money Laundering Workflows (online ed, Thomson Reuters) on Westlaw New Zealand.