FMA is seeking submissions on the practical implications of the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT Act) in situations where reporting entities are transacting with other reporting entities.

The consultation is in response to FMA's concerns over difficulties some reporting entities are having in determining aspects of their obligations under the AML/CFT Act to identify their customers' beneficial owners where the customer is itself a reporting entity.

The consultation is aimed at assisting reporting entities to develop and adopt practical processes and procedures to meet their AML/CFT obligations. FMA has prepared a draft "Factsheet on Managing Intermediaries" which supplements the Beneficial Ownership Guideline issued by the AML/CFT supervisors in December 2012.

Following the consultation, the AML/CFT supervisors will issue a finalised version of the factsheet which may contain additional or alternative practical advice for achieving compliance with obligations described in the factsheet.

Submissions close on 1 August 2013.

A copy of the consultation paper is available here.