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19 October 2022

InvestNow Saving and Investment Service Limited

The FMA has issued a formal warning to InvestNow Saving and Investment Service Limited for failing to comply with the Anti-Money Laundering and Countering Financing of Terrorism (AML/CFT) Act.

The FMA identified the issues with InvestNow through its routine monitoring for compliance with the Anti-Money Laundering and Countering Financing of Terrorism (AML/CFT) Act in November 2021 and June 2022.

In the FMA’s view, InvestNow failed to:

  • complete standard customer due diligence, including
    • obtaining sufficient information about the nature and purpose of the proposed business relationship from customers
    • taking reasonable steps to complete identity verification of customers and beneficial owners
  • conduct ongoing and/or enhanced customer due diligence on certain customers, including taking reasonable steps to verify source of wealth or funds
  • establish, implement and maintain an adequate and effective AML/CFT programme

The FMA is requiring InvestNow to:

  1. obtain information from its current customers to record their reasons for using the platform
  2. complete customer identity verification on its current customers, amend its onboarding process to ensure customer identity is properly verified, and provide training to staff on this process
  3. complete enhanced customer due diligence on customers that have made transactions which are complex, unusually large, or have an unusual pattern; amend its processes to ensure enhanced customer due diligence is undertaken when required; and provide training to staff on these processes
  4. complete ongoing customer due diligence on customers where there has been a material change (such as the information they have provided or their typical trading behaviour) in the customer’s relationship with InvestNow; amend its processes to ensure ongoing customer due diligence is undertaken when required; and provide training to staff on these processes
  5. review and revise its AML/CFT programme to ensure adequate and effective procedures are established for all types of customer due diligence and complex or unusually large transactions
  6. revise its AML/CFT programme based on an updated risk assessment that considers the nature, size, and complexity of its business, the products and services it offers, and the delivery methods of these products and services.

InvestNow must prepare a plan describing how and when it will complete these actions and submit it to the FMA by 31 October 2022. The company must also restrict withdrawals and transfers of financial products from customer accounts that require more information about their reasons for using the platform, identity verification, or further customer due diligence.