Compliance Guide 2026
New Zealand AML & Sanctions Compliance Guide
Expert guide to navigating New Zealand's AML/CFT and sanctions compliance landscape. Essential reading for banks, non-bank deposit takers, lawyers, accountants, real estate agents, and compliance officers operating in New Zealand.
New Zealand Compliance Overview
New Zealand Country Profile
New Zealand is a FATF member in good standing, regulated under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009. On 1 July 2026 the regime changed shape: the Department of Internal Affairs became the sole AML/CFT supervisor, replacing a three-supervisor model that had been in place since the Act commenced.
- DIA — Department of Internal Affairs; sole AML/CFT supervisor since 1 July 2026
- FIU — Financial Intelligence Unit within New Zealand Police; receives all reporting via goAML
- RBNZ and FMA — former AML/CFT supervisors; retain prudential and conduct roles respectively
Regulatory Framework
- Anti-Money Laundering and Countering Financing of Terrorism Act 2009
- AML/CFT (Supervisor, Levy, and Other Matters) Amendment Act 2026 — sole supervisor and industry levy, in force 1 July 2026
- AML/CFT Amendment Act 2026 — risk-based CDD and PEP determination, in force 19 May 2026
- United Nations Act 1946 — implements UN Security Council sanctions
Core obligations:
- Conduct a written risk assessment and maintain an AML/CFT programme
- Apply customer due diligence on a risk-based approach
- File Prescribed Transaction Reports (LCT and IFT) and Suspicious Activity Reports
- Submit an annual AML/CFT report and obtain an independent audit
The 2026 Supervisor Transition — What Changed
One Supervisor, Not Three
Before 1 July 2026, which regulator supervised you depended on what you did. The Reserve Bank supervised banks, life insurers and non-bank deposit takers; the Financial Markets Authority supervised designated business groups and section 130 entities; the DIA supervised everyone else. That distinction no longer exists.
- Banks and NBDTs — previously RBNZ, now DIA
- Insurers and fund managers — previously FMA or RBNZ, now DIA
- Lawyers, accountants, real estate, casinos — DIA throughout, unchanged
- Reporting — unchanged; still to the Police FIU via goAML
What Reporting Entities Should Do
- Check whether your AML/CFT programme names RBNZ or FMA as your supervisor and update it
- Re-read guidance against the DIA material reissued on 1 July 2026 — earlier guidance may be superseded
- Budget for the new industry levy, which funds supervisory and intelligence work
- Review CDD and PEP procedures against the risk-based approach introduced in May 2026
- Confirm your annual AML/CFT report due date with the DIA following the transition
Reporting Thresholds and Deadlines
Prescribed Transaction Reports
Two thresholds apply, and they are commonly conflated. Neither requires suspicion — both are mandatory once the threshold is met.
- Large Cash Transaction (LCT) — NZD 10,000 or more, domestic physical cash
- International Funds Transfer (IFT) — NZD 1,000 or more, where one institution is in New Zealand and one is outside it
The NZD 1,000 international threshold is low by international standards and captures a great deal of routine cross-border activity. Under-reporting of IFTs is among the most common failures for entities new to the regime.
Suspicious Activity Reports
Section 40 of the AML/CFT Act 2009 sets two deadlines, and which applies depends on what kind of business you are. There is no minimum transaction value, and the obligation applies whether or not the transaction completed.
- Three working days — reporting entities other than high-value dealers and law firms, s40(1)
- Five working days — law firms, s40(2)
- Three working days is tighter than many comparable jurisdictions
- The practical constraint is usually internal escalation speed, not detection
- Tipping off the customer is an offence
- Filing is through goAML, the FIU's reporting platform
Sanctions — A Specific New Zealand Gap
No General Autonomous Regime
New Zealand implements United Nations Security Council sanctions through the United Nations Act 1946. Unlike Australia, it has no general autonomous sanctions framework — the Russia Sanctions Act 2022 was passed as a standalone response, not as a broad power.
The consequence is easy to miss: a person or entity sanctioned by OFAC, the United Kingdom or the European Union may not appear on any New Zealand list, and screening against UN lists alone will not surface them.
What Adequate Screening Looks Like
- UN consolidated list — the legal minimum in New Zealand
- OFAC SDN — essential with US dollar clearing or US correspondent relationships
- UK OFSI and EU consolidated — for UK and European counterparties
- Russia Sanctions Act 2022 register — New Zealand's standalone regime
Compliance with New Zealand law and adequate management of sanctions risk are not the same standard here. Entities with international exposure should screen well beyond what the Act strictly requires.
Risk Typologies and Enforcement
Dominant Typologies
- Methamphetamine and drug proceeds — the dominant domestic predicate offence
- Real estate — used to place and layer proceeds
- Trade-based laundering — through import and export flows
- Fraud and scam proceeds — including investment and romance fraud
- Companies and trusts — used to obscure beneficial ownership
- Unregistered remitters and virtual assets — flagged in the 2021 FATF evaluation
Penalties
Civil pecuniary penalties under s90 are tiered by which civil liability act occurred:
- s78(b), (c), (d), (g) — up to NZD 100,000 individual / NZD 1,000,000 body corporate
- s78(a), (da), (e), (f), (h) — up to NZD 200,000 individual / NZD 2,000,000 body corporate
- Criminal, s100 — individual: up to 2 years imprisonment and/or NZD 300,000
- Criminal, s100 — body corporate or partnership: fine up to NZD 5,000,000
- Criminal, s102–103 — individual: up to 3 months and/or NZD 10,000
New Zealand's 2021 FATF mutual evaluation found a robust understanding of risk, supported by two National Risk Assessments and supervisor Sector Risk Assessments, while identifying beneficial ownership transparency and unregistered money or value transfer services as areas still to be addressed. The 2026 reforms respond to those findings.