Vanuatu

Section 34(1) requires a reporting entity to appoint an AML and CTF compliance officer. Section 33 covers the AML and CTF Procedure Manual and s 33(2A) requires periodic independent review by an external auditor.

Section 12 requires reporting entities to identify the customer and, under s 12(2)(c), any beneficial owner where a person acts for another. Verification is covered in s 16 and ongoing monitoring in s 17. The Regulation (Order 122 of 2014) sets the identification details and documents in cl. 3-4 and Schedule 2.

Section 19(3) requires transaction records to be kept for six years after the transaction is completed, and s 19(7) requires identity and verification records to be kept for six years after the account or relationship ends.

Section 37B(2) requires sender name, account number or tracing information and a further identifier for transfers of VT 100,000 or more, and s 37C sets sender and receiver requirements for international transfers below that. Sections 37B(9) and 37C(6) bar execution of a transfer if the information requirements are not met.

Clauses 12 and 13 set a VT 1 million reporting threshold for cash transactions and international currency transfers, with lower cash thresholds for some sectors. Reports are due within 10 working days for vatu and 2 working days for foreign currency (cl. 12(3)-(4), 13(2)-(3)).

Section 20(1) requires a suspicious transaction report to reach the VFIU not later than two working days after the suspicion arises; s 21 applies the same period to suspicious activity reports. Section 26(3) requires an oral report to be followed in writing within 24 hours.