Anti-Money Laundering and
Countering the Financing of Terrorism

Submissions on the third discussion document (Supervisory Framework)

The Hibernian Catholic Benefit Society

St Joseph's Branch No 962, Wellington

Secretary:
P M O'Brien
PO Box 10 326, The Terrace, Wellington,

26 October 2006

Ministry of Justice
PO Box 180
WELLINGTONM

Attn: Inter-agency Working Group on FATF Recommendations

Dear Working Group

AML/CFT

We received a letter some months ago seeking our views on "FATF" matters, but were unable to discern what it was about exactly, and so did not reply.

The process has evidently moved on, and I have read the latest document on your Ministry website. The matter is a bit clearer now, and so I make this reply. Sorry for being late.

You refer to"Core Principles" in respect of "fit and proper persons" for the top management of financial institutions (Rec.23). The organsizations supporting these Core Prinicples all have a very business and professional financial look about them. The committee of this Society, and I think most friendly societies, are a mixed bag. Although some are financially oriented, others are more community welfare minded. The committees of friendly societies are elected by the members (or their delegates) on the criteria they consider important. We would not want any laws which prevent democratic election.

I also note requirement for policies, procedures, controls training and audit (Recs 15,16). We would hope that this compliance burden will be tailored to suit the size of respective institutions. Both the number and size of transactions with friendly societies is small, especially branches, for which most are with people personally known to the officers.

Last, I thought the proposal that institutions be licensed was a bit drastic. Fines and publicity should be enough to ensure compliance.

I hope these comments are of help.

Yours sincerely
St Joseph's 962 Branch Hibernian Catholic Benefit Society

Philip O'Brien
Secretary