Understand what to expect as a new investor, when doing the AML component of Icehouse Ventures' onboarding process.
What is money-laundering?
Money laundering is defined as the criminal activity of disguising the illegal origins of wealth in order to protect, enjoy, and increase assets once illegal funds have been generated.
Anti-money laundering (AML) refers to the web of laws, regulations and procedures aimed at uncovering efforts to disguise illicit funds as legitimate income.
An overview of NZ's AML obligations
The Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT Act) places obligations on a number of New Zealand businesses, institutions, and organisations to detect and deter money laundering and terrorism financing.
The AML/CFT Act ensures these firms undertake 'customer due diligence' (CDD) to guard against money laundering, in particular by verifying the identities of their customers (or in the case of complex entities like companies and trusts, the people who control those).
How does Icehouse Ventures comply with AML regulations?
To ensure a seamless and highly secure process, Icehouse Ventures employs an AML agent (First AML) to manage the collection of customer information, so far as it relates to the AML process. A benefit of using First AML is once you have been verified using their platform, you can re-use the information there for future requests by other service providers. Similarly, if you have already been verified there, you will just need to authorise them to share your information with Icehouse Ventures.
What to expect
In the first instance, First AML will send you / the key contact for your investment vehicle a link to confirm your personal identity:
- For individuals - if you are investing as an individual, and completed the above form, there should be nothing further required from an AML perspective. However, note First AML will request a scan/photo of a deposit slip or bank statement just showing your preferred bank account name and number, for the purposes of distributions from Icehouse Ventures (i.e. sending money back to you by way of proceeds from investments you make on our platform).
- For complex entities (i.e. trusts, companies, partnerships) - after verifying your identity via the form above, First AML will request key documents / information needed to identify the investment entities 'controlling people' (i.e. trustees, directors, shareholders owning >25%). The documents requests will include trust deeds, partnership agreements, etc.
- Source of wealth - note that in the case of trusts (or any entity identified as requiring 'enhanced due diligence'), NZ regulations require First AML to collect evidence of 'source of wealth' (as distinct from evidence of wealth). Typically, this is most easily satisfied by providing either a set of trust accounts, or a letter from the trust's accountant or solicitor simply stating the source. More reading on this is here.
How will your information be used?
Your information will be used for the sole purpose of conducting CDD/KYC and identity verification. Your information will remain confidential and will not be shared outside of First AML or Icehouse Ventures without your consent.
If you are asked for AML information in the future, you may inform your service provider that you have already been verified with First AML. With your consent, First AML may be able to save you from repeating this process.
For more information, feel free to read First AML's Privacy Policy.
--
If you have any questions or require more clarification on Icehouse Ventures' AML/CFT compliance processes, please contact our Operations team.