FMA Enforcement Actions

Written By giulia dondoli

A couple of years ago, the Financial Markets Authority (FMA) issued a formal warning to InvestNow Savings and Investment Services Limited (InvestNow). At that time, the then FMA Director James Greig stated:

“DIY investing platforms are at a higher risk of being targeted for money laundering or terrorist funding due to the highly liquid and digital nature of their businesses […]. InvestNow failed to ensure it had the appropriate processes and controls to identify and respond to anomalies. Additionally, InvestNow was aware of its shortcomings but the company was slow to respond”
— James Greig

The FMA then conducted an investigation on InvestNow and concluded that the extent of the non-compliance warranted the commencement of civil proceedings.

In December 2024, the FMA filed civil proceedings against InvestNow for failing to:

  1. maintain an adequate AML/CFT programme;

  2. obtain information on the nature and purpose of the proposed business relationships;

  3. conduct enhanced customer due diligence;

  4. adequately conduct account monitoring; and

  5. terminate business relationships when required.

The FMA considers InvestNow’s failure to be significant and, in some aspects, systematic.

Internal Detection

The FMA is seeking a pecuniary penalty for InvestNow. In addition to that, InvestNow will likely need to undertake expensive remediation efforts and face potential reputational damages.

Ideally, you would want to detect any non-compliance issues internally, so that they can be addressed before a supervisory visit or investigation. Ways to detect potential aspects of AML/CFT non-compliance include:

  • Independent AML/CFT audit;

  • Internal assurance exercise, conducted by your AML/CFT compliance team; or

  • Assurance review conducted by an external provider.

Get in touch if you have any questions on how we can help you detect any potential non-compliance within your AML/CFT regime. We can help you with your statutory audit, guide you through an internal assurance exercise, or we can conduct the assurance review for you and issue you with a report.

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