This month, we reflect on key insights from the NZ FIU and ACAMS Conference in Wellington, examining the human cost of financial crimes, the complexities of proliferation financing, and why collaboration remains essential to effective financial crime prevention.
Story 1: Understanding the Human Cost of Financial Crime
The 2025 NZ FIU and ACAMS Conference brought together financial crime professionals under the theme "The New Financial Battlefield: Crime and the Global Power Shift." Jade ThirdEye has proudly sponsored this event since 2012, and this year's programme delivered particularly powerful reminders about why our work matters.
Beyond the Transactions: Real Harm, Real Victims
Financial crime isn't victimless. Behind every suspicious transaction lies a predicate offence causing genuine harm to real people. The conference featured presentations examining the devastating impact of various crime types, from transnational organised crime to environmental crimes and the methamphetamine epidemic affecting New Zealand communities.
One topic stood out for its particularly sobering impact: modern slavery. Approximately 50 million people worldwide currently suffer from various forms of modern slavery, including human trafficking, forced prostitution, and indebted labour on ships and in scam centres. These crimes generate substantial profits that flow through the financial system, creating both detection opportunities and responsibilities for financial institutions.
Modern Slavery in Australia and New Zealand
Whilst other countries may represent hotspots for modern slavery, Australia and New Zealand are far from immune. Recent court cases in New Zealand have prosecuted employers who brought workers into the country and exploited them, often threatening harm to their families back home if victims spoke out.
Australia's Modern Slavery Act requires larger companies to examine their supply chains for exploitation, but this responsibility extends beyond legal obligations. Any organisation committed to ethical business practices should review their entire supply chain to identify potential modern slavery concerns.
Detection Opportunities for Financial Institutions
Financial institutions can contribute to combating modern slavery through vigilant monitoring and reporting. The approach begins with foundational principles: understand your customer, their business, and the nature and purpose of their relationship with you. Monitor for behaviour patterns inconsistent with expected activity profiles.
Two distinct angles require different approaches. Detecting victims requires watching for signs of financial control and unusual account activity that suggests exploitation. Detecting perpetrators means identifying the financial patterns associated with trafficking operations and labour exploitation.
Australia has the Modern Slavery Act that requires larger companies to do this. But the subject has been gaining momentum and it should be good practice for any company to review the whole of their supply chain.
Story 2: Proliferation Financing – An Evolving Risk Requiring Focused Attention
Proliferation financing represents a relatively recent addition to AML/CFT regimes, but it demands serious attention from financial institutions across Australia and New Zealand.
Understanding the Scope
The FATF recommendations explicitly cover proliferation financing, and this has filtered down into national risk assessments. New Zealand's national risk assessment includes a dedicated section on proliferation financing, whilst Australia has published a comprehensive national risk assessment specifically for proliferation financing.
Proliferation financing extends beyond nuclear weapons to encompass all weapons of mass destruction, including chemical and biological weapons. The scope also covers materials used in creating these weapons, delivery systems, training, and various services including financial services.
Practical Implications for Financial Institutions
Companies supplying materials must consider potential uses, whilst financial institutions should monitor transactions that may support proliferation activities.
Building Effective Detection Capabilities
Financial institutions should start by reading the available risk assessments to understand proliferation financing risks comprehensively. Incorporate these risks into your own risk assessment, then design transaction monitoring specifically to address them.
As with modern slavery, it starts by understanding your customer then monitoring their behaviour. Amounts involved are often mid-range, so they're unlikely to get picked up by typical AML transaction monitoring rules which tend to focus more on high-value transactions.
The flow of funds is likely to be international, often from international hubs rather than directly from states involved in proliferation. Consider what transaction monitoring you need to specifically address any proliferation financing risks defined in your risk assessment.
Story 3: The Power of Collaboration in Fighting Financial Crime
Perhaps the most important theme emerging from the conference discussions was collaboration. Financial crime prevention cannot succeed in isolation, and various forms of collaboration strengthen our collective effectiveness.
Formal Collaboration Structures
The conference highlighted successful collaboration models, particularly the Financial Crime Prevention Network (FCPN) in New Zealand. This network includes NZ Police, banks, and various government agencies working together under an exemption that permits sharing information about suspicious activity and suspicious persons—something most reporting entities cannot do independently.
The FCPN has generated exponential improvements in detecting and preventing financial crimes by enabling participants to connect disparate pieces of information and identify patterns invisible to individual institutions. This demonstrates the power of structured information sharing when appropriate legal frameworks exist.
Conference presentations also discussed potential future collaboration tools, including a proposed database for reporting and accessing information about fraudsters. These initiatives reflect growing recognition that siloed approaches fundamentally limit our effectiveness against increasingly sophisticated criminal networks.
Informal Collaboration and Peer Learning
Collaboration doesn't always require formal structures or regulatory exemptions. Talking with peers represents one of the most valuable yet underutilised approaches to improving financial crime prevention.
Discover what's happening in other businesses, what detection approaches work effectively, and what generates unnecessary noise without genuine value. Then apply those learnings to your own operations, adapting successful strategies to your specific context.
The conference created ideal conditions for these discussions, but the real value comes from developing your professional network and continuing those relationships afterwards. Build connections with peers facing similar challenges, share insights generously, and learn from their experiences.
What This Means for ANZ Financial Institutions
The themes from this year's conference reinforce several critical priorities for financial crime professionals:
- Financial crime causes real harm to real people. Conference discussions revealed a concerning pattern: many people working at the operational level don't fully appreciate why their work matters. Every SAR you submit contributes to a larger intelligence picture, enabling agencies to take action against criminals. Attendees carry responsibility to share these insights with their entire teams, ensuring everyone understands how their daily work protects communities.
- Proliferation financing represents a genuine risk requiring specific attention and dedicated detection approaches. Review the available risk assessments, incorporate proliferation financing into your risk assessment, and design monitoring that addresses the unique characteristics of this threat.
- Collaboration amplifies effectiveness. Whether through formal structures like the FCPN or informal peer networks, sharing insights and learning from others makes everyone more effective at protecting customers and communities from financial crime.
Whether detecting modern slavery victims, monitoring for proliferation financing, or collaborating to stop fraud, the mission remains the same: protecting customers and communities from financial crime. Our podcast on identifying victims of exploitation explores practical approaches to victim detection, whilst the Skipton Building Society case study demonstrates how financial institutions can respond quickly to emerging threats, deploying new detection rules rapidly when suspicious activity is identified.
Stay vigilant and stay ahead. Join us next month for more Financial Crime insights, brought to you by Jade ThirdEye.
This blog is based on the November episode of The FinCrime Connection ANZ, hosted by Jing Zhang, Business Development Manager, and Colin Dixon, CAMS-certified AML Solutions Specialist at Jade ThirdEye. Colin has been with Jade ThirdEye since its inception in 2012 and brings extensive experience helping clients maximise the effectiveness of their financial crime prevention programmes.