Individual Customer Risk Ratings (ICRR) went live on 1st June 2025. From this date, all reporting entities are required to risk rate their clients at the point of onboarding, and consider risk as part of ongoing CDD.
We have developed a number of resources for real estate front line agents and Admin/AMLCO staff on how the AMLHUB platform and app has incorporated ICRR. Please see below to access these:
Guides
Definitions
See the definitions for the new fields in the AMLHUB platform, below.
Property on-sold quickly: this definition would be determined by your reporting entity. Currently the industry is using between 3-12 months. If your client purchased the property in the last 3-12 months and is listing it now, it could be considered as property on-sold quickly.
New developer: this definition would be determined by the reporting entity. A developer could be considered new if they were incorporated in the last 12-24 months.
Company with multiple layers: a company that has multi-layer ownership, i.e., a company that has multiple shareholders that are entities that have further shareholding ownership.
High net-worth individual: there is no set definition for this and it is reporting-entity dependent.
Foreign exposure: if the client owns any property outside of NZ, which country is this? Did they use income received from outside of NZ for the current transaction (to buy the property)? Do they live outside of NZ for three or more months in the year?
Used for personal assets: was the company set up to hold personal assets, not to operate as a business? For example: the company was set up to hold the owner's occupied property or rental investment property.
Nominee Directors or Shareholders: was the Director/Shareholder on the Companies Register nominated on behalf of someone else? If so, they will not make the decisions or control the assets of the entity. If the nominee Director/Shareholder exists, that means there is someone else who has effective control and beneficial interest that is not reflected on the Companies Register.
Webinars
6th June | AMLHUB ICRR Changes for Real Estate Admin / AML Compliance Officers
Feat. Tijana Misur, Head of Audit & Consulting, AML Solutions; and Eilidh Penman, Chief Operating Officer, AMLHUB Group
Access video here: https://vimeo.com/1091052536/4d3645031e?share=copy
19th May | AMLHUB ICRR Changes for Real Estate Front Line Staff
Access video here: https://vimeo.com/1085563656/8776e91adf?share=copy
19th May | AMLHUB ICRR Changes for Real Estate Admin / AML Compliance Officers
Feat. Tijana Misur, Head of Audit & Consulting, AML Solutions; and Eilidh Penman, Chief Operating Officer, AMLHUB Group
Access video here: https://vimeo.com/1085564243/e7bb84ddb6?share=copy
21st May | AMLHUB ICRR Changes for Real Estate Admin / AML Compliance Officers
Feat. Eilidh Penman, Chief Operating Officer, AMLHUB Group
Access video here: https://vimeo.com/1086560787/9f6ef0ae31?share=copy
Mobile App Demo Video
Access video here: https://vimeo.com/1085566552/587b303241?share=copy
