Automated Submission of PTRs: A Guide for Reporting Entities
Introduction
In today’s increasingly digital landscape, reporting entities are under pressure to streamline their operations while meeting regulatory requirements. The automated submission of Prescribed Transaction Reports (PTRs) is one way to achieve this goal.
Challenges of Developing an Automated Solution
Developing an automated solution requires specialized technical expertise and resources. Without the necessary IT skills or access to such expertise, developing an automated solution can be challenging. Additionally, budget constraints can pose a significant hurdle as automated submission of PTRs requires investment in technology and resources to prepare, maintain, and upgrade the solution.
Benefits of Automated Submission
On the other hand, reporting entities that expect to submit high volumes of transactions may find the benefits of an automated solution outweigh the costs. By submitting many transactions at once, automated submission can significantly reduce manual workload and minimize errors.
Testing Prescribed Transaction Reports
Before accessing the production environment, reporting entities must successfully complete a testing process with the Financial Intelligence Unit (FIU). This involves three key stages:
- Establishing a successful connection to the NZ Police goAML testing environment
- Validating files at the schema level
- Completing multiple manual file reviews with the FIU
Test File Preparation
During the testing phase, reporting entities should test files covering all scenarios they are required to report under legislation and regulations. Some common scenarios include:
- Inward international funds transfers
- Outward international funds transfers
- Large cash deposits
- Large cash withdrawals
- Currency exchanges
It is essential to use obfuscated test data that cannot be used to identify individuals, entities, or accounts.
File Review Template
Once testing is complete, reporting entities must submit the PTR File Review Template to the FIU. The purpose of this review is to assist the FIU in understanding the context behind transactions and identify any areas where mandatory information may be missing. After feedback is provided on the first file review, reporting entities will need to submit further reviews until the FIU is satisfied with the quality, accuracy, and compliance of the test reports.
Legislation and Guidance Documents
Reporting entities are encouraged to familiarize themselves with relevant legislation and guidance documents, including:
- AML/CTF Act
- PTR Guidance
Additional Resources
For more information on submitting PTRs, reporting entities can refer to their sector supervisor or visit the following websites:
- Department of Internal Affairs (DIA)
- Financial Markets Authority (FMA)
- Reserve Bank of New Zealand (RBNZ)
Alternatively, reporting entities can consult our PTR FAQ Document, which provides answers to frequently asked questions collaboratively determined by the FIU, Ministry of Justice, and sector supervisors. If you are still unable to find an answer to your question, please email us.
Conclusion
Automated submission of PTRs is a complex process that requires specialized technical expertise and resources. By understanding the testing requirements and investing in an automated solution, reporting entities can streamline their operations while meeting regulatory obligations. With careful planning and execution, reporting entities can successfully navigate this critical aspect of AML/CFT compliance.