Background
The Financial Markets Authority (FMA) issued a formal warning to InvestNow Saving and Investment Service Limited for significant non‑compliance with the Anti‑Money Laundering and Countering Financing of Terrorism (AML/CFT) Act. The issues were identified through the FMA’s routine AML/CFT compliance monitoring conducted in November 2021 and June 2022
The FMA concluded that InvestNow failed to meet several core AML/CFT obligations, including completing standard customer due diligence, obtaining sufficient information on the nature and purpose of customer relationships, and taking reasonable steps to verify customer and beneficial owner identities. Additional deficiencies were identified in InvestNow’s approach to ongoing and enhanced customer due diligence, particularly in relation to verifying sources of wealth or funds and responding to complex, unusually large, or unusual transaction patterns. The FMA also found that InvestNow did not establish, implement, or maintain an AML/CFT programme that was adequate and effective for the nature of its business.
In response, the FMA has required InvestNow to undertake a comprehensive remediation programme. This includes collecting additional information from existing customers regarding their reasons for using the platform, completing identity verification for current customers, and amending onboarding processes to ensure robust verification going forward. InvestNow must also strengthen its enhanced and ongoing due diligence processes, supported by staff training, and revise its AML/CFT programme to ensure it adequately addresses all customer due diligence requirements and the management of complex or unusual transactions. These revisions must be based on an updated risk assessment that reflects the nature, size, and complexity of InvestNow’s business, products, services, and delivery methods.
As part of the enforcement timeline, InvestNow was required to submit a remediation plan to the FMA by 31 October 2022 and to restrict certain customer withdrawals and transfers where required information or due diligence had not been completed.
More recently, in December 2024, the FMA escalated its response by filing civil proceedings against InvestNow for alleged breaches of the AML/CFT Act 2009, marking a significant progression in regulatory action.
