How to File SARs & PTRs Correctly in NZ

Anti-money laundering (AML) reporting is a critical responsibility for businesses in New Zealand. Failure to correctly submit Suspicious Activity Reports (SARs) or Prescribed Transaction Reports (PTRs) can result in compliance breaches and regulatory penalties. This guide outlines the correct process for filing SARs and PTRs, ensuring compliance with the AML/CFT Act.

What Are SARs and PTRs?

Before outlining the filing process, it is important to understand the purpose of these reports and when they must be submitted.

Suspicious Activity Reports (SARs)

A SAR must be submitted when a business suspects that a transaction or customer behaviour may be linked to money laundering or terrorism financing. The purpose of a SAR is not to prove criminal activity but to alert the authorities to potentially suspicious financial activity for further investigation.

Examples of activities that may require a SAR include:

Large cash transactions with no logical business purpose
Rapid movement of funds between unrelated accounts
A customer refusing to provide identity or source of funds information

For more details on SAR reporting requirements, visit the New Zealand Police Financial Intelligence Unit (FIU) SAR reporting page.

Prescribed Transaction Reports (PTRs)

A PTR must be filed for certain high-value transactions, regardless of whether they are suspicious. In New Zealand, these include:

International wire transfers of NZD 1,000 or more
Large cash transactions of NZD 10,000 or more

PTRs are required because large or cross-border transactions can be used to facilitate money laundering, organised crime, fraud, and tax evasion. More information on PTR requirements is available on the New Zealand Police FIU.

How to File a SAR in New Zealand

The process for filing a SAR involves three key steps.

Identify Suspicious Activity

Businesses must have a risk-based approach to transaction monitoring and Ongoing Customer Due Diligence (OCDD) to detect suspicious activity. Suspicious activity may be identified based on sector-specific risk indicators, as outlined in the Sector Risk Assessments published by the Department of Internal Affairs.

Some common red flags for money laundering in New Zealand include:

Transactions structured just below reporting thresholds
Frequent high-value cash deposits with no clear business purpose
Customers using multiple accounts to conduct similar transactions

Gather Required Information

When submitting a SAR, businesses must provide:

Customer details (full name, date of birth, address, and account information)
Transaction details (amount, date, currency, payment method)
The reason for suspicion, with a detailed explanation of the activity that triggered the report

For a complete list of reporting requirements, refer to the FIU’s SAR reporting guidelines Police.govt.nz.

Submit the SAR via goAML

All SARs in New Zealand must be submitted electronically through the goAML portal, which is managed by the FIU. Businesses must first register for access and ensure their compliance teams are trained in using the platform.

How to File a PTR in New Zealand

Unlike SARs, PTRs are mandatory reports that must be submitted for qualifying transactions.

Determine if the Transaction Meets PTR Criteria

A PTR must be submitted for:

Any international wire transfer of NZD 1,000 or more
Any large cash transaction of NZD 10,000 or more

More details on prescribed transaction reporting requirements can be found on the FIU’s PTR page.

Collect Required Information

A PTR must include:

Sender and recipient details (full name, date of birth, and address)
Transaction details (amount, currency, payment method)
Bank or financial institution details involved in the transfer

Submit the PTR via goAML

Like SARs, PTRs must be filed through the goAML platform. Reporting entities should ensure they have a compliance officer responsible for timely submission of these reports.

Best Practices for AML/CFT Reporting Compliance

To ensure compliance with SAR and PTR requirements, businesses should:

Regularly train staff on identifying suspicious transactions
Implement automated transaction monitoring to flag potential risks
Maintain clear internal reporting procedures
Ensure SAR and PTR reporting is integrated into their AML/CFT compliance programme, as outlined in the AML/CFT Programme Guideline
Stay updated with regulatory changes by following guidance from the DIA, FIU, and FMA

Need Help with AML Compliance?

Filing SARs and PTRs correctly is just one part of a robust AML/CFT compliance programme. If your business needs expert guidance on AML advisory services, risk assessments, or bespoke compliance programme documentation, Seamless AML can help.

Learn more about our AML compliance services at Seamless AML.

Conclusion

Accurate and timely filing of SARs and PTRs is essential for compliance with New Zealand’s AML/CFT framework. Businesses must ensure they have robust processes in place for identifying suspicious activity, gathering required information, and submitting reports through goAML. By following best practices and staying informed about regulatory updates, reporting entities can help safeguard New Zealand’s financial system against money laundering and terrorism financing.

For tailored AML/CFT compliance support, visit Seamless AML today.