Anti-Money Laundering (AML) Policy for TAG The Agency Limited

1. Purpose

This Anti-Money Laundering (AML) Policy outlines TAG The Agency’s commitment to comply with the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT Act) in New Zealand. The purpose of this policy is to prevent, detect, and report money laundering and terrorist financing activities while ensuring the integrity of the agency’s services and reputation.

2. Scope

This policy applies to all employees, contractors, consultants, and any other individuals or entities acting on behalf of TAG The Agency in New Zealand. It governs all business activities, including advertising, marketing, and financial transactions.

3. Definitions

  • Money Laundering: The process of disguising illegal sources of money to make them appear legitimate.

  • Terrorist Financing: The provision of funds for terrorist activities, whether from legitimate or illegitimate sources.

  • Customer Due Diligence (CDD): The process of verifying the identity of clients and assessing their risk for money laundering or terrorist financing.

4. Legal Framework

This policy is based on the requirements set out by:

  • The Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT Act)

  • The Financial Transactions Reporting Act 1996

  • Guidance provided by the Financial Markets Authority (FMA), the Department of Internal Affairs (DIA), and the Reserve Bank of New Zealand (RBNZ).

5. Key Principles

5.1. Customer Due Diligence (CDD)

TAG The Agency will conduct appropriate due diligence on all clients prior to engaging in any services to:

  • Verify the identity of clients and their beneficial owners.

  • Understand the nature of the client’s business and the purpose of the engagement.

  • Assess the risk of money laundering or terrorist financing based on the client profile, geographic location, and the nature of the advertising services requested.

5.2. Enhanced Due Diligence (EDD)

Where the agency identifies a higher risk of money laundering or terrorist financing, Enhanced Due Diligence (EDD) will be conducted, which may include:

  • Further verification of identity.

  • Detailed inquiries into the client’s source of funds or wealth.

  • Monitoring ongoing transactions more closely.

5.3. Record Keeping

TAG The Agency will maintain accurate and up-to-date records of:

  • Client identities.

  • CDD and EDD procedures and outcomes.

  • Any suspicious activity reports (SARs) filed. All records will be retained for a minimum of five years after the end of the business relationship.

5.4. Suspicious Activity Reporting (SAR)

If any employee of TAG The Agency suspects that a client or transaction is involved in money laundering or terrorist financing, they must report it to the Compliance Officer, who will assess whether to file a Suspicious Activity Report (SAR) with the New Zealand Financial Intelligence Unit (FIU). The SAR will be filed confidentially and within 3 working days if required.

5.5. Ongoing Monitoring

The agency will continuously monitor business relationships, reviewing transactions and changes in client behaviour to detect any potential red flags or suspicious activities.

6. Roles and Responsibilities

6.1. Compliance Officer

The Compliance Officer is responsible for:

  • Overseeing the implementation of this AML policy.

  • Conduct regular reviews of the policy and related procedures.

  • Ensuring all employees receive training on AML regulations and their responsibilities.

  • Filing SARs when necessary.

6.2. Employees

All employees of TAG The Agency are required to:

  • Understand and comply with this policy.

  • Report any suspicious behavior or transactions to the Compliance Officer.

  • Complete mandatory AML training provided by the agency.

7. Training and Awareness

TAG The Agency will provide regular training to all staff, ensuring they are aware of:

  • The requirements of the AML/CFT Act.

  • How to identify suspicious transactions or activities.

  • The process of reporting suspicious activities to the Compliance Officer.

8. Compliance Monitoring and Auditing

The Compliance Officer will conduct regular internal audits of TAG The Agency’s compliance with AML requirements. The results of these audits will be reviewed by senior management and used to improve the effectiveness of the policy.

9. Penalties for Non-Compliance

Failure to comply with the AML/CFT Act may result in legal penalties, including fines and imprisonment, as well as reputational damage to TAG The Agency. Any employee found to be intentionally violating this policy will face disciplinary action, up to and including termination of employment.

10. Review of Policy

This policy will be reviewed annually or as required by changes in legislation, regulatory requirements, or business practices. Any updates will be communicated to all employees.