Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved.

Financial Integrity Monitor

New Zealand NZ

Domains covered
8 of 8
Sources
168
Role actions
8
Horizon <90d
0
Jurisdiction profile
FATF status: Largely Compliant Tier: B Risk direction: Stable Enablement vs enforcement: Mixed

AML/CFT Act 2009 (extended 2018 to all DNFBP sectors) with three supervisors — RBNZ, FMA, DIA — and NZ Police FIU (NZPFIU).

MoreStrong ML prosecution/asset-forfeiture record but historically weak targeted financial sanctions implementation and beneficial ownership transparency; in FATF enhanced follow-up since 2021 MER.

Key deficiencies
  • Beneficial ownership information availability for legal persons/arrangements remains incomplete despite 2022 register bill
  • Targeted financial sanctions (TFS) implementation historically minimal — no assets frozen under TFS regimes as of 2021 MER, cited again in 2024 follow-up
  • Banking-sector AML/CFT supervision under-resourced relative to sector size
  • Nominee director/trustee and foreign-trust structures retain residual opacity despite post-Panama Papers reforms
  • 11 of 40 FATF Recommendations remain only partially compliant as of the July 2024 follow-up report
Recent developments (18m)
  • FATF's 3rd Enhanced Follow-Up Report (18 July 2024) re-rated New Zealand on Recommendations 14, 16, 19, 22 and 23, moving it to compliant on 8 and largely compliant on 21 Recommendations, while retaining enhanced follow-up status
  • ICIJ's April 2026 ten-years-after-Panama-Papers retrospective documents the continuing effect of New Zealand's post-2016 foreign trust disclosure reform on reducing offshore trust registrations
  • FATF's February 2025 Plenary amendments to Recommendation 1 (proportionality/simplified measures) create a pending domestic alignment task for New Zealand's risk-based AML/CFT framework
  • Beneficial ownership register bill (introduced 2022 following Pandora Papers) continues phased implementation without a confirmed full public-register date
Brief

Lead signal

Lead Signal

New Zealand's financial integrity regime produced a confirmed enforcement outcome this cycle: the High Court has imposed a NZ$1.425 million civil penalty on The Co-operative Bank Limited, agreed on a consent basis, for deficient transaction-monitoring rules, inadequate assurance testing of monitoring systems, and insufficient record-keeping under the AML/CFT Act 2009. The conduct underlying the penalty dates to at least 2020, but the case is notable for its procedural context as much as its substance: supervisory responsibility for the bank passed from the Reserve Bank of New Zealand to the Department of Internal Affairs on 1 July 2026, when DIA became New Zealand's sole Anti-Money Laundering supervisor for all reporting entities, replacing the prior three-supervisor model split across DIA, the Financial Markets Authority and the Reserve Bank. No actual laundering was alleged against the bank; the penalty rests entirely on control-design and control-operation failures.

Read full brief

Lead Signal

New Zealand's financial integrity regime produced a confirmed enforcement outcome this cycle: the High Court has imposed a NZ$1.425 million civil penalty on The Co-operative Bank Limited, agreed on a consent basis, for deficient transaction-monitoring rules, inadequate assurance testing of monitoring systems, and insufficient record-keeping under the AML/CFT Act 2009. The conduct underlying the penalty dates to at least 2020, but the case is notable for its procedural context as much as its substance: supervisory responsibility for the bank passed from the Reserve Bank of New Zealand to the Department of Internal Affairs on 1 July 2026, when DIA became New Zealand's sole Anti-Money Laundering supervisor for all reporting entities, replacing the prior three-supervisor model split across DIA, the Financial Markets Authority and the Reserve Bank. No actual laundering was alleged against the bank; the penalty rests entirely on control-design and control-operation failures.

The significance lies in sequencing. This is the second civil AML/CFT court penalty against a New Zealand registered bank in under five months, following an earlier case against ASB. Two penalties against retail banks inside half a year, arriving just as the consolidated supervisor model beds in, reads as a structural signal rather than an isolated incident: it indicates DIA is both willing and equipped to carry enforcement momentum forward from the prior fragmented-supervisor era, rather than treating the transition as a pause in oversight.

Other Developments

A sole-supervisor model now in its fifth month of operation. DIA's assumption of full AML/CFT supervisory authority on 1 July 2026 consolidated what had been a split jurisdiction across three regulators. The Co-operative Bank matter is the clearest evidence yet that the handover did not create a supervisory gap: enforcement that originated under RBNZ oversight has been carried through to a concluded court outcome under the new unified structure.

A reform Bill now in suspended animation. The Anti-Money Laundering and Countering Financing of Terrorism (Omnibus) Amendment Bill, described as the fourth and final instrument in DIA's AML/CFT reform programme, was introduced before Parliament but its progress has paused following the dissolution of Parliament on 1 October 2026 ahead of the general election scheduled for 7 November 2026. The Bill as introduced would integrate financial-sanctions screening duties into the AML/CFT framework and expand DIA's enforcement toolkit; it would also provide a one-year good-faith transitional period from 31 December 2026 for the expiry of the managing-intermediaries exemption. None of this has been enacted, and its fate now depends on the composition of the next Parliament. A primary-source pinpoint citation for the transitional good-faith mechanism was not independently retrieved this cycle; the available account rests on secondary legal commentary.

Cross-Monitor Connections

The consolidation of AML/CFT supervisory authority under a single regulator, and the enforcement record that regulator is now building, is directly relevant to any monitor tracking payment-sector compliance exposure in New Zealand, since reporting entities across banking and non-banking payment channels now answer to one supervisor with one enforcement posture rather than three. The pending Omnibus Bill's proposed integration of financial-sanctions screening duties into the AML/CFT framework is also a natural point of connection for monitors tracking sanctions architecture more broadly, since it would fold a previously separate compliance obligation into the same statutory structure DIA now administers end to end.

Outlook

The near-term picture is procedural rather than substantive: the Omnibus Bill's progress is suspended until after the 7 November 2026 election, and its ultimate shape, including the proposed sanctions-screening integration and the transitional arrangements for the managing-intermediaries exemption, will depend on the next government's legislative priorities. Independent of that legislative uncertainty, the enforcement trend is the more durable signal. With two bank-level civil penalties concluded within five months and a newly consolidated supervisor now exercising sole authority, reporting entities should expect that the transition to the single-supervisor model has not softened enforcement expectations around transaction-monitoring design, assurance testing, and record-keeping. The next dated marker is the general election itself; the Bill's progress, and therefore the fate of the sanctions-screening integration, cannot be assessed as scheduled until a new Parliament is seated.

Earlier periodic briefs (6)
4 Nov 2026 · fim-2026-11-04

Lead Signal

New Zealand's financial integrity regime produced a confirmed enforcement outcome: the High Court has imposed a NZ$1.425 million civil penalty on The Co-operative Bank Limited, agreed on a consent basis, for deficient transaction-monitoring rules, inadequate assurance testing of monitoring systems, and insufficient record-keeping under the AML/CFT Act 2009. The conduct underlying the penalty dates to at least 2020, but the case is notable for its procedural context as much as its substance: supervisory responsibility for the bank passed from the Reserve Bank of New Zealand to the Department of Internal Affairs on 1 July 2026, when DIA became New Zealand's sole Anti-Money Laundering supervisor for all reporting entities, replacing the prior three-supervisor model split across DIA, the Financial Markets Authority and the Reserve Bank. No actual laundering was alleged against the bank; the penalty rests entirely on control-design and control-operation failures.

The significance lies in sequencing. This is the second civil AML/CFT court penalty against a New Zealand registered bank in under five months, following an earlier case against ASB. Two penalties against retail banks inside half a year, arriving just as the consolidated supervisor model beds in, reads as a structural signal rather than an isolated incident: it indicates DIA is both willing and equipped to carry enforcement momentum forward from the prior fragmented-supervisor era, rather than treating the transition as a pause in oversight.

Other Developments

A sole-supervisor model now in its fifth month of operation. DIA's assumption of full AML/CFT supervisory authority on 1 July 2026 consolidated what had been a split jurisdiction across three regulators. The Co-operative Bank matter is the clearest evidence yet that the handover did not create a supervisory gap: enforcement that originated under RBNZ oversight has been carried through to a concluded court outcome under the new unified structure.

A reform Bill now in suspended animation. The Anti-Money Laundering and Countering Financing of Terrorism (Omnibus) Amendment Bill, described as the fourth and final instrument in DIA's AML/CFT reform programme, was introduced before Parliament but its progress has paused following the dissolution of Parliament on 1 October 2026 ahead of the general election scheduled for 7 November 2026. The Bill as introduced would integrate financial-sanctions screening duties into the AML/CFT framework and expand DIA's enforcement toolkit; it would also provide a one-year good-faith transitional period from 31 December 2026 for the expiry of the managing-intermediaries exemption. None of this has been enacted, and its fate now depends on the composition of the next Parliament. A primary-source pinpoint citation for the transitional good-faith mechanism was not independently retrieved; the available account rests on secondary legal commentary.

Cross-Monitor Connections

The consolidation of AML/CFT supervisory authority under a single regulator, and the enforcement record that regulator is now building, is directly relevant to any monitor tracking payment-sector compliance exposure in New Zealand, since reporting entities across banking and non-banking payment channels now answer to one supervisor with one enforcement posture rather than three. The pending Omnibus Bill's proposed integration of financial-sanctions screening duties into the AML/CFT framework is also a natural point of connection for monitors tracking sanctions architecture more broadly, since it would fold a previously separate compliance obligation into the same statutory structure DIA now administers end to end.

Outlook

The near-term picture is procedural rather than substantive: the Omnibus Bill's progress is suspended until after the 7 November 2026 election, and its ultimate shape, including the proposed sanctions-screening integration and the transitional arrangements for the managing-intermediaries exemption, will depend on the next government's legislative priorities. Independent of that legislative uncertainty, the enforcement trend is the more durable signal. With two bank-level civil penalties concluded within five months and a newly consolidated supervisor now exercising sole authority, reporting entities should expect that the transition to the single-supervisor model has not softened enforcement expectations around transaction-monitoring design, assurance testing, and record-keeping. The next dated marker is the general election itself; the Bill's progress, and therefore the fate of the sanctions-screening integration, cannot be assessed as scheduled until a new Parliament is seated.

3 Nov 2026 · fim-2026-11-01

Lead Signal

New Zealand's High Court has confirmed a NZ$1.425 million civil penalty against The Co-operative Bank Limited for breaches of the AML/CFT Act 2009, centred on deficient transaction-monitoring rules, inadequate assurance testing of those monitoring systems, and insufficient record-keeping. The conduct underlying the penalty dates to at least 2020. The case was carried through to judgment by the Department of Internal Affairs (DIA), which became New Zealand's sole AML/CFT supervisor on 1 July 2026, taking over matters previously within the Reserve Bank of New Zealand's supervisory remit. The architectural point is the one worth foregrounding: this is not simply an enforcement data point against one bank, it is the newly consolidated supervisor demonstrating continuity of casework across a machinery-of-government handover, confirming that a change in which agency holds the pen does not reset the clock on matters already in train.

The substantive findings go to the core obligations every reporting entity carries under the AML/CFT Act: a monitoring programme adequate to the institution's risk profile, periodic assurance testing of that programme's actual performance rather than its design on paper, and record-keeping sufficient to reconstruct the entity's compliance posture after the fact. A penalty of this size against a smaller, member-owned bank signals that the AML/CFT Act's core obligations are being applied without regard to institutional scale.

Other Developments

A fourth and final reform Bill reached Parliament before the AML/CFT programme stalled on the electoral calendar. The Anti-Money Laundering and Countering Financing of Terrorism (Omnibus) Amendment Bill was introduced as the last instalment in DIA's multi-year reform programme, proposing to integrate financial-sanctions screening duties directly into the AML/CFT framework, to expand DIA's enforcement toolkit, and to increase penalties available against reporting entities. Parliament was dissolved on 1 October 2026 ahead of the 7 November 2026 general election, which means the Bill's progress is paused pending the incoming Parliament's legislative priorities rather than abandoned. One transitional element survives the pause regardless of the Bill's fate: a one-year good-faith period from 31 December 2026 covering the expiry of the managing-intermediaries exemption, giving affected firms a defined runway to adjust their intermediary arrangements before the exemption's withdrawal bites in earnest.

DIA's consolidation of supervisory authority continues to generate guidance volume alongside enforcement activity. Since assuming sole AML/CFT supervisor status on 1 July 2026, DIA has published a substantial body of new and updated guidance material for reporting entities navigating the consolidated regime. Taken together with the Co-operative Bank judgment, the picture is of a supervisor using both the enforcement docket and the guidance channel simultaneously to establish the practical content of obligations that, on their face, have not changed in wording but are being interpreted and applied with a single institutional voice for the first time.

Cross-Monitor Connections

The transaction-monitoring and record-keeping deficiencies underlying the Co-operative Bank penalty sit squarely at the intersection of this monitor's AML/CTF regime coverage and payments-infrastructure oversight of the same institutions: a bank found wanting on monitoring-programme adequacy is a bank whose payment-rail risk controls merit independent scrutiny, even though no payments-specific finding is recorded against it. Separately, the proposed integration of financial-sanctions screening into the AML/CFT framework under the stalled Omnibus Bill is the kind of structural convergence - sanctions compliance and AML compliance collapsing into a single supervisory ask - that is relevant to conflict-finance and sanctions-evasion analysis elsewhere in the fleet's coverage, even though New Zealand's own sanctions posture generated no independent development.

Outlook

The Omnibus Bill's fate now rests with the Parliament elected on 7 November 2026; as scheduled, the one-year good-faith period for the managing-intermediaries exemption begins on 31 December 2026 regardless of the Bill's own progress, so firms relying on that exemption have a defined, dated transition window even while the broader legislative reform sits in abeyance. DIA's demonstrated willingness to carry forward and win a substantial civil penalty inherited from its predecessor supervisor suggests reporting entities should not read the July 2026 consolidation of supervisory authority as a reset of enforcement priorities, but as a continuation of them under a single institutional roof.

25 Oct 2026 · fim-2026-10-25

Lead Signal

New Zealand's anti-money laundering architecture reached a consolidation milestone. From 1 July 2026 the Department of Internal Affairs became the countrys sole AML/CTF supervisor for all reporting entities, replacing the three-supervisor model that had split oversight across the Department, the Financial Markets Authority and the Reserve Bank. The change took legal effect under the AML/CFT (Supervisor, Levy, and Other Matters) Amendment Act 2026, which received assent on 18 May 2026. An industry levy intended to help fund the consolidated supervisor remains subject to separate Cabinet approval and has not been confirmed as commenced, so the funding model trails the supervisory handover by an unresolved interval.

Alongside the supervisory consolidation, the fourth and final phase of New Zealands multi-year AML/CFT reform programme reached Parliament. The AML/CFT (Omnibus) Amendment Bill was introduced on 1 September 2026 and has been described by the Associate Minister of Justice as the most substantial overhaul of the regime since the Act was passed in 2009. The Bill would replace the existing designated business group concept with separate mandatory reporting group and voluntary reporting group structures, each carrying its own group-wide programme obligations. Notably, the Bill also establishes, for the first time, a dedicated statutory framework for targeted financial sanctions inside the AML/CFT Act itself, and would permit the AML/CFT supervisor to disclose relevant information to the Police, the New Zealand Security Intelligence Service and the Government Communications Security Bureau.

Other Developments

Risk-based PEP identification continues its gradual embedding. The reform programme is carrying forward a shift toward a risk-based standard for determining whether a customer or beneficial owner is a politically exposed person, rather than a fixed categorical test. This is a continuation of direction already present in earlier amendment Acts rather than a standalone new development, but it remains material to enhanced due diligence practice for reporting entities, including banks and cross-sector obliged entities.

A domestic sanctions-architecture gap is being addressed structurally rather than through a listing change. The Omnibus Bills targeted financial sanctions framework is a domestic-architecture development: it does not alter New Zealands alignment or divergence from EU, US or UK sanctions lists, but it does create, for the first time, a dedicated statutory mechanism inside the AML/CFT Act for targeted financial sanctions, alongside the existing Russia Sanctions Act 2022 and the UN-based terrorism-suppression regime. The information-sharing gateway to the Police, the Security Intelligence Service and the Government Communications Security Bureau is a parallel structural feature of the same Bill.

The timing of full enactment sits downstream of the general election. Because the Omnibus Bill was introduced ahead of a general election, its Select Committee process and further readings are expected to fall to the next Government, with full enactment anticipated in 2027 or 2028. New Zealands next FATF mutual evaluation is understood to be expected in 2028, which is reported as one driver of the reform timetable, though no FATF primary-source confirmation of that date was located.

DIA has issued a substantial volume of new and updated guidance since assuming sole supervisory responsibility, reflecting the practical work of consolidating oversight that had previously been split across three agencies.

Cross-Monitor Connections

The online casino gambling licensing programme running in parallel, in which the Department of Internal Affairs also plays a central role as sector regulator, sits adjacent to the AML/CTF supervisory consolidation: the same Department that now holds sole AML/CTF supervisory authority over reporting entities also regulates the newly licensed online casino gambling sector, concentrating both financial-crime supervision and sectoral licensing judgment in one agency. This is a structural observation about institutional concentration rather than a finding that gambling-sector money-laundering risk has itself changed.

Outlook

The near-term picture for reporting entities, including gambling operators once licensed, is one of a longer compliance runway than the Omnibus Bills text alone would suggest: its substantive restructuring of reporting-entity obligations, including the move to mandatory and voluntary reporting groups and the new targeted financial sanctions framework, will not bind until the next Government completes the Bills passage, plausibly not before 2027 or 2028. Two open questions will shape how quickly that changes: whether the Bill is referred to a Select Committee before or after the election, and whether DIA confirms commencement of the AML/CFT supervisory levy that remains subject to separate Cabinet approval. Both would sharpen the compliance timetable considerably if resolved sooner than the current multi-year expectation.

18 Oct 2026 · fim-2026-10-18

Lead Signal

New Zealand's AML/CFT reform programme reached a structural milestone this cycle. The Department of Internal Affairs became the country's sole AML/CFT supervisor from 1 July 2026, replacing the prior three-regulator model that had split oversight across DIA, the FMA and the Reserve Bank. Building on that consolidation, the AML/CFT (Omnibus) Amendment Bill was introduced to Parliament on 1 September 2026 as the fourth and final phase of the reform programme. The Bill is reported to give reporting entities more flexibility on risk-based customer due diligence, create mandatory reporting groups, strengthen FIU and DIA enforcement and account-freezing powers, and embed a new "specified sanction" concept that would integrate targeted financial sanctions directly into the AML/CFT compliance framework. Taken together, the supervisory consolidation and the Omnibus Bill represent an architectural rebalancing of how New Zealand structures AML/CFT compliance obligations, rather than an incremental rule change.

Other Developments

Crypto-asset classification by designation, not legislation. New Zealand continues to have no bespoke stablecoin or crypto-asset statute. The Financial Markets Authority's designation notice concerning the NZDD stablecoin, reported 11 March 2026, declared that NZDD is not a "financial product" because it pays no interest and functions instead as a payment or remittance instrument. This remains the only concrete classification precedent in the jurisdiction, and it was reached through a case-specific designation process rather than a general legislative framework.

FATF standing unchanged. New Zealand remains off both the FATF grey list and black list, assessed as compliant on 9 Recommendations, largely compliant on 25, and partially compliant on 6, with a fifth-round mutual evaluation still pending. No adverse FATF signal was identified this cycle.

Cross-Monitor Connections

The Omnibus Bill's proposed "specified sanction" concept, which would integrate targeted financial sanctions screening directly into the AML/CFT compliance framework, has a direct read-across to sanctions-screening obligations for gambling operators and other reporting entities already tracked elsewhere in this fleet. The FMA's NZDD stablecoin designation is relevant to crypto and digital-asset monitoring: a payment-instrument classification outside the financial-product perimeter has implications for how New Zealand-domiciled stablecoin activity is treated under parallel payments and crypto-specific regimes.

Outlook

The Omnibus Bill's passage through Parliament is the development to watch. If enacted as reported, it would double the maximum money-laundering sentence from 7 to 14 years, introduce an infringement-offence regime, and require reporting entities to screen for "specified sanctions" as part of standard AML/CFT compliance, alongside the shift to risk-based CDD flexibility and mandatory reporting groups. As at 18 October 2026, the Bill had not been enacted and no select-committee timeline had been independently confirmed. The structural direction is clear and sits against the backdrop of a supervisory consolidation already in force since 1 July 2026, but the substantive compliance impact for reporting entities depends on the Bill's final enacted terms.

12 Oct 2026 · fim-2026-10-12

Lead Signal

New Zealand's financial-integrity architecture is caught between two speeds this cycle. On the administrative side, consolidation has landed: the Department of Internal Affairs became the sole AML/CFT supervisor from 1 July 2026, collapsing what had been a three-supervisor model shared with the Reserve Bank and the Financial Markets Authority. On the legislative side, momentum has stalled. The AML/CFT (Omnibus) Amendment Bill, introduced on 1 September 2026 as the final stage of New Zealand's reform programme, was still before Parliament when Parliament was dissolved on 1 October 2026 ahead of the 7 November 2026 general election. Enactment now falls to whichever government forms after the vote, and the Bill carries with it New Zealand's first proposed standalone targeted-financial-sanctions framework, risk-based simplified customer due diligence, repeal of the existing reliance-letter safe harbour, strengthened Financial Intelligence Unit powers including temporary account freezing, and a regulation-making power to impose cash-payment restrictions on remittance and virtual-asset transfers.

That last element is itself a retreat from an earlier, more sweeping proposal. The government has abandoned an outright ban on crypto ATMs in favour of the narrower cash-restriction power, with any consultation on how that power would be used deferred to early 2027. Taken together, the supervisory consolidation that has already taken effect and the reform package that has not amount to a jurisdiction moving in two directions at once: tidier institutionally, less certain legislatively.

Other Developments

Earlier reform already in force. Before the Omnibus Bill stalled, two related instruments had already delivered incremental relief. The AML/CFT Amendment Act 2026 came into force on 19 May 2026, delivering customer due diligence and risk-assessment relief that industry had sought, and the Anti-Money Laundering and Countering Financing of Terrorism (Supervisor, Levy, and Other Matters) Amendment Act 2026 is the instrument that installed DIA as sole supervisor from 1 July 2026. The Omnibus Bill was to be the capstone of this sequence, consolidating further CDD simplification and the new sanctions and FIU powers; its deferral leaves the reform programme substantially, but not wholly, implemented.

Crypto-ATM policy narrows rather than disappears. The shift from an outright ban to a targeted cash-payment restriction, paired with a regulation-making power rather than a self-executing rule, signals a government choosing to preserve flexibility over imposing an immediate blanket prohibition on virtual-asset cash access points. Deferring consultation to early 2027 means the operative detail of how that power will be used remains unset, and now awaits a different Parliament's priorities entirely.

FATF review timing remains a commentary estimate. Legal commentary places New Zealand's next FATF mutual evaluation at around 2028, though this is the commentators' own forward expectation rather than a date confirmed by FATF itself, and should be read with that caveat attached.

Cross-Monitor Connections

The proposed targeted-financial-sanctions framework inside the stalled Omnibus Bill would be New Zealand's first standalone sanctions architecture, distinct from its current reliance on the Russia Sanctions Act and United Nations Act regimes; a world-payments reading of this jurisdiction should note that the framework's fate is now tied to electoral timing rather than legislative drafting risk. The crypto-ATM cash-restriction power, meanwhile, sits at the boundary of crypto-asset infrastructure policy and payments-rail access, relevant to any crypto-monitor tracking jurisdictions narrowing physical on/off-ramp access short of prohibition.

Outlook

The near-term picture turns entirely on the 7 November 2026 election outcome and whatever government forms afterward. If the incoming Parliament reintroduces or carries forward the Omnibus Bill substantially unchanged, New Zealand would gain simplified risk-based CDD, its first sanctions framework, and expanded FIU powers within a reasonably short window; if priorities shift, the Bill could be redrafted or shelved, leaving DIA's sole-supervisor model as the only durable structural change from this reform cycle. The crypto-ATM consultation, already pushed to early 2027, is unlikely to move faster than the Bill itself. Firms operating in or into New Zealand should treat the current framework, including the 19 May 2026 CDD relief and the 1 July 2026 supervisory consolidation, as the stable baseline, and the Omnibus Bill's further changes as contingent rather than scheduled.

28 Sep 2026 · fim-2026-09-28

Lead Signal

New Zealand's AML/CFT supervisory architecture was structurally reconsolidated this cycle. The AML/CFT (Supervisor, Levy, and Other Matters) Amendment Act 2026 took effect on 1 July 2026, making the Department of Internal Affairs New Zealand's sole AML/CFT supervisor for all reporting entities, replacing the prior tri-supervision model that had split responsibility across the Reserve Bank of New Zealand, the Financial Markets Authority and DIA. The Act also grants DIA new rule-making, investigation and censure powers, introduces an industry levy, and mandates a National Strategy, marking a governance overhaul rather than an incremental adjustment. Separately, the AML/CFT Amendment Act 2026 came into force 19 May 2026, moving Source of Wealth and Source of Funds verification from an automatic-trigger standard to a risk-based one, alongside a new 'money or value transfer service' definition. This is architecture-over-incident territory: the significance lies in the redesigned supervisory perimeter and verification standard, not in any single enforcement action.

Other Developments

Beneficial ownership register recommitted, timeline uncertain. On 20 December 2025, New Zealand's Associate Police Minister unveiled a TSOC strategy renewing commitment to a beneficial-ownership register for companies and limited partnerships, to be overseen by the Ministry of Business, Innovation and Employment. Implementation sits within a five-year-horizon Priority 2 action, meaning it could plausibly slip beyond 2027 rather than delivering on any near-term basis. New Zealand continues to rely on Companies Office shareholder disclosure in the interim, a mechanism that can list nominee shareholders or trusts rather than natural-person beneficial owners, leaving the underlying transparency gap unresolved for now.

Crypto-asset service providers formally captured as financial institutions. FMA guidance confirms that crypto-asset service providers offering a 'financial service' are captured as 'financial institutions' under the AML/CFT Act, with DIA now the sole supervisor for those reporting entities from 1 July 2026, the same date the broader supervisory consolidation took effect. This closes what had been ambiguity in how CASPs sat within New Zealand's AML/CFT perimeter, folding digital-asset supervision into the same consolidated architecture as every other reporting-entity sector.

Cross-Monitor Connections

The DIA sole-supervisor consolidation and the CASP capture finding both intersect directly with the crypto monitor's tracking of New Zealand's stablecoin-designation and tax-reporting developments this cycle, since the same 1 July 2026 date anchors the AML/CFT supervisory change referenced there. The world-payments monitor's tracking of New Zealand's consumer-credit conduct consolidation under the FMA, effective the same day, 1 July 2026, is a parallel but distinct regulatory-consolidation story; both reflect a broader pattern of New Zealand regulatory perimeters being redrawn around the FMA and DIA in mid-2026, though the underlying statutes and supervised activities differ.

Outlook

The Government has signalled intent to introduce a further Bill amending the AML/CFT Act within the current parliamentary term, expected around the first quarter of 2027, following this cycle's supervisory and definitional amendments; the scope of that further amendment has not yet been detailed. On beneficial ownership, the practical test will be whether the Priority 2, five-year-horizon commitment translates into a Bill or Cabinet paper within the next reporting cycles, or continues to slip. New Zealand's FATF standing remains unchanged and stable throughout: it is not on the grey list, and its 3rd enhanced follow-up report records it as compliant or largely compliant on 34 of 40 Recommendations.

Domain intelligence (D1–D8)

D1 Sanctions

no_changestanding position

Sanctions Architecture and Evasion

New Zealand tightened its autonomous Russia sanctions programme on 20 February 2026, when the Ministry of Foreign Affairs and Trade amended the Russia Sanctions Regulations 2022 to add 23 individuals, 13 entities and 100 vessels to its designations list, and to cut the Russian crude-oil price cap to USD44.10. This is an autonomous, UN-independent action: New Zealand operates its own sanctions-listing power under domestic legislation rather than transposing UN Security Council designations, and this amendment continues a listing cadence that tracks the G7 coalition's oil-price-cap strategy against Russian crude exports rather than introducing a New Zealand-specific sanctions theory. For financial institutions and trade-finance counterparties, the amendment is a screening-list update event: designated individuals, entities and vessels must be reflected in sanctions-screening systems, and the tightened price cap has direct relevance to trade-finance and shipping-insurance counterparties handling Russian-origin crude. No New Zealand-specific sanctions-evasion typology or enforcement action was identified against NZ-domiciled entities this cycle; the development is confined to the designation and price-cap amendment itself.

Continue reading

Outlook

The next marker to watch is whether New Zealand's autonomous programme continues to track further G7 coordination on the oil price cap, or diverges in either direction. No NZ-specific sanctions-evasion case or enforcement action is currently pending disclosure this cycle.

D2 Beneficial Ownership

no_changestanding position

Beneficial Ownership and Corporate Transparency

Globally, the EU AML Package, comprising the AML Regulation (Reg (EU) 2024/1624, directly applicable across Member States), the sixth AML Directive (6AMLD, transposed per Member State), and the AMLA Regulation (Reg (EU) 2024/1620) establishing the Anti-Money Laundering Authority, sets the structural direction for beneficial-ownership transparency internationally, shifting supervision from purely national authorities toward a hybrid EU-level regime through AMLA's direct and indirect supervision perimeter. New Zealand sits outside this package's direct perimeter, as it is not an EU or EEA jurisdiction; the directly relevant developments for New Zealand's own beneficial-ownership posture are domestic.

Continue reading

On 20 December 2025, New Zealand's Associate Police Minister unveiled a TSOC strategy renewing the Government's commitment to implement a beneficial-ownership register for companies and limited partnerships, to be overseen by the Ministry of Business, Innovation and Employment. This is a recommitment rather than a new proposal, and its implementation profile is notably unhurried: it is a Priority 2 action within a five-year timeframe, which means the register could plausibly slip to 2027 or beyond rather than being delivered in the near term. In the absence of the register, New Zealand continues to rely on Companies Office shareholder disclosure, a mechanism that can list nominee shareholders or trusts rather than the natural-person beneficial owners a register is designed to surface, leaving a persistent transparency gap between what is disclosed and who ultimately controls a corporate structure.

The durable backdrop against which this cycle's New Zealand-specific signal should be read is therefore twofold: internationally, the EU's move toward AMLA-anchored hybrid supervision represents a structural tightening of beneficial-ownership expectations; domestically, New Zealand's own register remains a stated but unimplemented commitment, with the gap between commitment and delivery itself a form of standing exposure for corporate-structure opacity that could be exploited by illicit actors seeking a jurisdiction where nominee arrangements are not pierced by a public register.

Outlook

The test for New Zealand's beneficial-ownership trajectory is whether the Priority 2, five-year-horizon TSOC commitment converts into a Cabinet paper or Bill within the next several reporting cycles, or continues to be recommitted without material implementation progress. No primary Cabinet paper or Bill text was available this cycle, so this sub-brief's signal rests on NGO and press reporting of the Ministerial announcement rather than the underlying instrument itself.

Standing baseline position

Committed (Priority 2, five-year horizon) per December 2025 TSOC strategy; no public BO register yet in place.

D3 Enabler Jurisdictions

no_changestanding position

Enabler Jurisdictions and Professional Facilitators

New Zealand's enabler-jurisdiction risk architecture underwent a structural consolidation this cycle. From 1 July 2026, the Department of Internal Affairs became the sole AML/CFT supervisor for all New Zealand reporting entities, replacing the previous RBNZ/FMA/DIA tri-agency model and funded by an industry levy. Architecture-over-incident framing applies directly here: a single-supervisor model removes the seams between three previously distinct supervisory perimeters and materially expands DIA's reach into DNFBP and cross-sector obliged entities, a structural change more analytically significant than any single enforcement action taken under the prior model. This consolidation lands against a backdrop of sustained enforcement activity against the casino and trust/company-service-provider sector: Christchurch Casinos Limited incurred a NZD5.06 million AML/CFT penalty for breaches dated 20 October 2025, and the same enforcement period included enforceable undertakings against Lexington Trust Services and Pagemark, a NZD1.125 million penalty against Qian DuoDuo, and a NZD4.16 million SkyCity settlement. Read together, DIA's new sole-supervisor status inherits an already-active enforcement programme rather than initiating enforcement afresh, suggesting continuity of enforcement intensity through the supervisory transition rather than a pause.

Continue reading

New Zealand's own structural transparency position is unchanged this cycle: the jurisdiction continues to rely on private-sector customer due diligence rather than a public beneficial-ownership register, a gap that persists alongside, rather than being resolved by, the supervisory consolidation.

The industry-levy funding model underpinning DIA's expanded mandate is itself a structural signal: shifting supervisory funding from general taxation to a sector-specific levy typically strengthens a regulator's independence and resourcing stability, a factor relevant to assessing whether the consolidated supervisor can sustain enforcement intensity at the level demonstrated against the casino and TCSP sector this period. For professional facilitators — trust and company service providers, casinos, and other DNFBP-category reporting entities — the practical effect of consolidation is a single point of supervisory contact and a single set of guidance and reporting expectations, replacing what had been a tri-agency division of labour that could create seams for regulatory arbitrage between sectors supervised by different agencies.

Regionally, Cambodia presents a contrasting enabler-jurisdiction risk profile. The National Bank of Cambodia's governor publicly warned in January 2026 of a possible third FATF grey-list placement tied to casino- and scam-centre-linked money laundering, an implicit concession of prior state under-enforcement, and provincial enforcement activity intensified in the same period. This is a capacity-deficit pattern distinct in kind from New Zealand's own posture, where enforcement capacity is demonstrably active but the underlying transparency infrastructure remains a standing gap; Cambodia's exposure is structural and enforcement-capacity-driven, tied specifically to the casino and scam-centre sector that has separately drawn New Zealand's own domestic enforcement attention.

Outlook

Whether DIA's consolidated supervisory model translates into materially different enforcement outcomes, rather than continuity of the existing casino/TCSP enforcement programme, is the key domestic marker to watch next cycle. Regionally, Cambodia's exposure to a third FATF grey-list placement is the enabler-jurisdiction development most likely to generate a discrete materiality trigger in a subsequent cycle.

D4 Conflict Finance

no_change

No NZ-specific conflict-finance development identified this cycle.

D5 Crypto / Digital Assets / Financial Innovation

no_changestanding position

Crypto / Digital Assets / Financial Innovation

New Zealand's Cabinet reversed course on crypto-ATM regulation this cycle, abandoning an in-principle blanket ban in favour of targeted regulation-making powers over cash-to-virtual-asset transactions, to be delivered through the forthcoming AML/CFT Omnibus Amendment Bill expected to be introduced in the third quarter of 2026. This is a calibrated rather than prohibitive policy choice: rather than banning a payment channel outright, the government is opting for cash-transaction threshold powers that can be tuned to risk rather than eliminating the channel. This decision reflects a broader FATF-aligned trend toward risk-based virtual-asset controls, and this specific claim carries Assessed rather than High confidence, corroborated by two independent tier-3 sources but without primary bill text yet available.

Continue reading

The reversal sits alongside two other digital-asset developments this cycle. New Zealand's OECD Crypto-Asset Reporting Framework obligations took effect on 1 April 2026, extending cross-border tax-transparency reporting to crypto-asset service providers operating in or serving New Zealand. Separately, the Financial Markets Authority determined that the NZDD stablecoin, issued by Easy Crypto/ECDD Holdings, is not a financial product under the Financial Markets Conduct Act 2013, effective 11 March 2026, subject to reserve, disclosure and verification conditions, with the explicit condition that yield-bearing features would revert the product to regulated status. Taken together, the ATM policy reversal, the CARF reporting obligation, and the stablecoin product determination describe a jurisdiction building calibrated, product-specific digital-asset controls rather than either a prohibitive stance or an unregulated gap.

Outlook

The forthcoming AML/CFT Omnibus Amendment Bill is the key instrument to watch, since primary bill text will convert the currently Assessed-confidence crypto-ATM reversal into a directly sourceable legislative development. Continued monitoring of the NZDD stablecoin's product design — specifically whether it remains non-yield-bearing — will determine whether it remains outside the financial-product perimeter.

Standing baseline position

FMA declared the ECDD Holdings NZDD stablecoin not a 'financial product' under the FMC Act, in force 11 March 2026; CARF reporting obligations for reporting crypto-asset service providers take effect 1 April 2026.

Periodic updates (3)
18 Oct 2026 · fim-2026-10-18

Crypto, Digital Assets, and Financial Innovation

New Zealand continues to regulate crypto-assets through general financial-markets law rather than any bespoke crypto or stablecoin statute. The Financial Markets Authority's designation notice concerning the NZDD stablecoin, issued by ECDD Holdings/Easy Crypto and reported 11 March 2026, declared that NZDD is not a "financial product" under the Financial Markets Conduct Act framework because it pays no interest or return and functions as a payment or remittance instrument rather than an investment product. This designation remains the only concrete regulatory precedent for stablecoin classification in the jurisdiction, and it was reached through a discretionary, case-specific designation process rather than a general licensing or issuance-authorisation regime. A multi-year legislative roadmap for stablecoin-specific regulation has been reported, but no bill addressing stablecoin issuance, reserve backing or redemption rights has yet been introduced to Parliament.

For financial-crime risk purposes, the absence of a bespoke framework means stablecoin and broader crypto-asset activity in New Zealand sits largely outside dedicated prudential or disclosure obligations, relying instead on whichever general financial-markets or AML/CFT provisions happen to apply to the activity in question. The DIA's new status as sole AML/CFT supervisor from 1 July 2026, and the AML/CFT (Omnibus) Amendment Bill's reported integration of a "specified sanction" concept, are both structurally relevant to how crypto-asset service providers in New Zealand will be expected to screen counterparties going forward, even though neither development is crypto-specific by design.

Outlook

The trajectory to watch is whether New Zealand's reported multi-year stablecoin legislative roadmap advances to an actual bill. Absent that, the NZDD designation will likely continue to function as the de facto precedent against which any future stablecoin product seeking New Zealand distribution is assessed. The passage of the Omnibus Bill, with its proposed sanctions-screening integration, would also indirectly shape AML/CFT expectations for crypto-asset operators once enacted, though as at 18 October 2026 it remained before Parliament.

12 Oct 2026 · fim-2026-10-12

Crypto, Digital Assets, and Financial Innovation

New Zealand's approach to crypto-ATM regulation has moved from a proposed outright ban to a narrower, regulation-making power targeting cash payments associated with virtual-asset transfers, including those made through crypto ATMs. This recalibration is contained within the AML/CFT (Omnibus) Amendment Bill, introduced on 1 September 2026, and reflects a policy choice to preserve case-by-case or future rule-making flexibility rather than impose an immediate blanket prohibition on a specific access-point technology. Consultation on how the regulation-making power will actually be exercised has been deferred to early 2027, meaning the operative substance of the restriction, who it applies to, what cash thresholds trigger it, and how it would be enforced, remains unset.

The timing complicates this picture considerably. The Omnibus Bill was still before Parliament when Parliament was dissolved on 1 October 2026 ahead of the 7 November 2026 general election, so the crypto-ATM provision's fate now depends on a government that does not yet exist. A jurisdiction that chooses targeted controls over prohibition is making a meaningfully different bet than one that bans outright: it preserves the channel while reserving the right to constrain its use, which is a materially different posture for exchanges, ATM operators, and the virtual-asset transfer ecosystem that relies on cash on/off-ramps. Whether that bet survives a change of government, or an incoming administration prefers a harder line, is now an open question rather than a drafting detail.

No New Zealand-specific finding this cycle extends the crypto/digital-asset picture beyond this single regulatory development; the sources reviewed are law-firm and policy trackers closely corroborating the same underlying facts about the Bill's contents, rather than independent primary-instrument text. The absence of a reviewed primary text for the regulation-making power itself is a genuine gap, not a gap in research effort, and it means the probable-confidence framing attached to the mechanism's exact scope should be read as provisional until the Bill, or its successor, resumes its passage.

Outlook

The crypto-ATM cash-restriction power is unlikely to move toward consultation before early 2027 at the earliest, and that timeline itself depends on the Omnibus Bill being carried forward substantially intact by the government that forms after the 7 November 2026 election. If a new government reworks or deprioritises the Bill, the crypto-ATM provision could be redrafted, delayed further, or replaced with a different mechanism entirely, including a return to the originally mooted outright ban. Firms operating crypto ATMs or facilitating cash-based virtual-asset transfers in New Zealand currently face no new statutory restriction beyond the existing AML/CFT framework, and should treat the targeted cash-restriction power as a signalled but not yet operative development.

28 Sep 2026 · fim-2026-09-28

Crypto, Digital Assets, and Financial Innovation

In New Zealand, the directly relevant digital-asset development this cycle is the formal capture of crypto-asset service providers within the AML/CFT supervisory perimeter. FMA guidance confirms that crypto-asset service providers offering a 'financial service' are captured as 'financial institutions' under the AML/CFT Act, and from 1 July 2026 the Department of Internal Affairs became the sole AML/CFT supervisor for those reporting entities, the same date on which DIA's broader consolidation as sole AML/CFT supervisor for all reporting-entity sectors took effect. This means New Zealand CASPs no longer sit in a supervisory grey zone between financial-services regulators; they are folded into the same consolidated supervisory architecture as banks, non-bank lenders and other financial institutions.

Globally, structural developments such as the OECD's Crypto-Asset Reporting Framework and evolving FATF virtual-asset guidance form contextual backdrop to how jurisdictions approach digital-asset AML/CFT supervision, but the New Zealand-specific finding this cycle is squarely about domestic supervisory consolidation rather than about international standard-setting. The practical effect for CASPs operating in or into New Zealand is that DIA is now the single point of AML/CFT supervisory contact and enforcement authority, replacing what had previously been ambiguity as to whether a given CASP's activities fell within RBNZ, FMA or DIA's respective remits under the prior tri-supervision model.

This consolidation is structural rather than incident-driven: no CASP-specific enforcement action was identified this cycle, and the significance of the development lies in the clarified and unified supervisory perimeter itself, consistent with an architecture-over-incident reading of the New Zealand digital-asset AML/CFT landscape.

Outlook

Whether DIA's consolidated supervisory role produces a distinct CASP-specific supervisory approach, such as sector-specific guidance or risk assessments, or whether CASPs are supervised under the same generic reporting-entity framework as other sectors, is the practical question to watch. The absence of any CASP-specific enforcement action this cycle should be read as a function of the consolidation being newly effective from 1 July 2026, not as an indication of enforcement inactivity going forward.

D6 Compliance Technology & Active Defence

no_change

No NZ-specific RegTech/compliance-technology development identified this cycle.

D7 AML/CTF Regime

escalating

AML/CTF Regime

The defining event of this cycle is the High Court's confirmation of a NZ$1.425 million civil penalty against The Co-operative Bank Limited, agreed on a consent basis, for deficient transaction-monitoring rules, inadequate assurance testing of those monitoring systems, and insufficient record-keeping under the AML/CFT Act 2009. The underlying conduct dates to at least 2020. No actual laundering was alleged; the penalty is a pure control-architecture failure, the kind of finding that speaks to how a reporting entity's compliance function was built and tested rather than to any specific illicit flow it missed.

Continue reading

The procedural backdrop gives the case added weight. Supervisory responsibility for the bank passed from the Reserve Bank of New Zealand to the Department of Internal Affairs on 1 July 2026, the date on which DIA became New Zealand's sole Anti-Money Laundering supervisor across all reporting entities, replacing a model that had split authority across DIA, the Financial Markets Authority and the Reserve Bank. That the first concluded enforcement outcome under the new consolidated model is a carried-over case from the old RBNZ-supervised banking sector indicates institutional continuity through the handover, not a gap in oversight during the transition. This is also the second civil AML/CFT court penalty against a New Zealand registered bank inside five months, following an earlier matter involving ASB, which strengthens the reading of this as a sustained enforcement posture rather than a single data point.

Separately, the Anti-Money Laundering and Countering Financing of Terrorism (Omnibus) Amendment Bill, the fourth and final instrument in DIA's reform programme, was introduced before Parliament but its progress has paused following the dissolution of Parliament on 1 October 2026 ahead of the general election scheduled for 7 November 2026. As introduced, the Bill would integrate financial-sanctions screening duties directly into the AML/CFT statutory framework and expand DIA's enforcement tools, and it would provide a one-year good-faith transitional period from 31 December 2026 for the expiry of the managing-intermediaries exemption. None of this is yet law, and a primary-source pinpoint for the transitional mechanism was not independently retrieved this cycle, leaving the account resting on secondary legal commentary rather than the Bill text itself.

Outlook

The enforcement trajectory and the legislative trajectory are moving on different clocks. Enforcement is active and ongoing under the new sole-supervisor model regardless of what happens in Wellington; the Omnibus Bill's fate, including its proposed sanctions-screening integration, cannot be assessed as scheduled until a new Parliament is seated after the 7 November 2026 election. Reporting entities should expect that the transition to unified DIA supervision has done nothing to soften expectations around transaction-monitoring design, assurance testing, and record-keeping, independent of how the reform Bill ultimately resolves.

Cumulative analysis

AML/CTF Regime

New Zealand's AML/CFT regime underwent two structural amendments this cycle. First, the AML/CFT (Supervisor, Levy, and Other Matters) Amendment Act 2026 took effect 1 July 2026, consolidating the Department of Internal Affairs as sole AML/CFT supervisor for all reporting entities and replacing the prior tri-supervision model split across the Reserve Bank of New Zealand, the Financial Markets Authority and DIA. The Act grants DIA new rule-making, investigation and censure powers, introduces an industry levy on the sector it supervises, and mandates a National Strategy, representing a governance overhaul of New Zealand's AML/CFT supervisory design rather than an incremental adjustment to an existing model.

Second, the AML/CFT Amendment Act 2026 came into force 19 May 2026, introducing a new 'money or value transfer service' definition and moving Source of Wealth and Source of Funds verification from an automatic-trigger standard to a risk-based one. This is a definitional and verification-standard change with practical compliance implications: reporting entities no longer apply SoW/SoF verification uniformly on an automatic basis but instead calibrate verification intensity to assessed risk, a shift that reduces blanket compliance burden while placing greater emphasis on the quality of each entity's own risk assessment.

New Zealand's FATF standing remains stable and unchanged through both amendments: the jurisdiction is not on the FATF grey list, and its 3rd enhanced follow-up report, following the 2021 Mutual Evaluation, records compliance on 9 Recommendations and large compliance on 25 of the 40 FATF Recommendations, with 6 partially compliant. The domestic amendments this cycle are consistent with continued alignment toward, rather than departure from, that standing FATF assessment.

Outlook

The Government has signalled intent to introduce a further Bill amending the AML/CFT Act within the current parliamentary term, with a broad expectation the process may extend into early 2027; the specific scope of that further amendment was not detailed this cycle. Whether DIA's newly consolidated censure and investigation powers translate into visible enforcement activity, and how reporting entities adapt to risk-based SoW/SoF verification in practice, are the near-term indicators to watch for whether this cycle's structural changes deliver a materially different supervisory experience.

domain_sub_briefs · D7 · Cumulative analysis
Standing baseline position

AML/CFT (Omnibus) Amendment Bill introduced to Parliament 1 September 2026 as the fourth and final reform phase; DIA has been sole AML/CFT supervisor since 1 July 2026.

Risk-based Source of Wealth/Source of Funds verification standard, in force 19 May 2026.

Department of Internal Affairs is NZ's sole AML/CFT supervisor from 1 July 2026, replacing the prior DIA/FMA/RBNZ three-supervisor model; industry levy pending separate Cabinet approval.

Periodic updates (4)
3 Nov 2026 · fim-2026-11-01

AML/CTF Regime

The defining development for New Zealand's AML/CTF regime is the High Court's confirmation of a NZ$1.425 million civil penalty against The Co-operative Bank Limited. The penalty rests on three findings: a transaction-monitoring programme that did not meet the standard the AML/CFT Act 2009 requires, assurance testing of that programme that was inadequate to catch its own shortfalls, and record-keeping insufficient to demonstrate the bank's compliance posture after the fact. The underlying conduct is reported as dating to at least 2020, meaning the judgment resolves a matter that long predates the most recent round of institutional reform.

The institutional context matters as much as the dollar figure. The Department of Internal Affairs (DIA) became New Zealand's sole AML/CFT supervisor on 1 July 2026, consolidating a function that had previously sat in part with the Reserve Bank of New Zealand for registered banks. This case was carried forward to judgment by DIA notwithstanding the handover, which is itself a signal: reporting entities should not assume that a machinery-of-government consolidation interrupts or dilutes pending enforcement matters. The architecture-over-incident reading is that DIA is demonstrating continuity of casework as a feature of the consolidated regime, not treating 1 July 2026 as a clean slate.

Alongside enforcement, DIA's guidance output has been substantial since it took on sole-supervisor status, with new and updated guidance documents issued to reporting entities navigating the consolidated regime. This combination, a live and willing enforcement docket paired with an active guidance programme, is consistent with a supervisor using both channels to establish the practical content of obligations whose statutory wording has not itself changed.

The forward-looking element of the regime is the Anti-Money Laundering and Countering Financing of Terrorism (Omnibus) Amendment Bill, described as the fourth and final instalment in DIA's multi-year reform programme. It proposes to integrate financial-sanctions screening duties into the AML/CFT framework itself, to expand DIA's enforcement tools, and to raise available penalties. The Bill was introduced before Parliament was dissolved on 1 October 2026 ahead of the 7 November 2026 general election, so its substantive progress is now paused pending the composition and priorities of the incoming Parliament rather than abandoned outright. One element is dated independently of that uncertainty: a one-year good-faith period beginning 31 December 2026 applies to the expiry of the managing-intermediaries exemption, giving firms relying on that exemption a defined transition runway regardless of how quickly, or whether, the wider Bill proceeds.

The pinpoint statutory provisions breached by The Co-operative Bank have not been independently retrieved, and the specific penalty-setting provision under which the civil penalty was calculated likewise remains to be sourced to primary legislation. Both gaps are noted for completeness rather than treated as settled.

Outlook

The near-term question is whether the Omnibus Bill is reintroduced in substantially the same form once the new Parliament is seated, or whether its sanctions-screening integration and expanded enforcement provisions are revised during that process; as scheduled, neither outcome affects the 31 December 2026 start of the managing-intermediaries good-faith period, which proceeds on its own statutory timeline. Reporting entities, particularly registered banks, should expect DIA's demonstrated willingness to pursue inherited enforcement matters to continue, meaning the consolidation of supervisory authority under one agency is better read as continuity of scrutiny than as a pause in it.

25 Oct 2026 · fim-2026-10-25

AML/CTF Regime

New Zealand's AML/CTF supervisory architecture completed a long-planned consolidation. From 1 July 2026 the Department of Internal Affairs became the countrys sole AML/CTF supervisor for all reporting entities, a change given legal effect by the AML/CFT (Supervisor, Levy, and Other Matters) Amendment Act 2026, which received assent on 18 May 2026. This replaces the prior three-supervisor model that had split responsibility across the Department, the Financial Markets Authority and the Reserve Bank. An industry levy intended to help fund the consolidated supervisor remains subject to separate Cabinet approval and has not been confirmed as commenced, leaving the funding mechanism unresolved even as supervisory authority itself has already transferred. Since assuming sole responsibility, DIA has issued a substantial volume of new and updated guidance, consistent with the practical task of harmonising oversight previously split across three agencies with differing approaches and reporting lines.

Against that consolidated supervisory backdrop, the fourth and final phase of New Zealand's multi-year AML/CFT reform programme reached Parliament on 1 September 2026, when the AML/CFT (Omnibus) Amendment Bill was introduced. The Associate Minister of Justice has described it as the most substantial overhaul of the regime since the Act was passed in 2009. Structurally, the Bill would retire the existing designated business group concept and replace it with two distinct structures: a mandatory reporting group, which would be required to maintain a group-wide AML/CFT programme, and a voluntary reporting group. It also carries forward the existing direction toward a risk-based standard for determining whether a customer or beneficial owner is a politically exposed person, a continuation of an approach already present in earlier amendment Acts rather than a new development. A separate but related structural feature of the Bill is the creation, for the first time, of a dedicated statutory framework for targeted financial sanctions inside the AML/CFT Act itself, together with a gateway permitting the AML/CFT supervisor to disclose relevant information to the Police, the New Zealand Security Intelligence Service and the Government Communications Security Bureau.

The practical significance of the Bill for reporting entities, including gambling operators moving through New Zealand's separate online casino licensing process, is tempered by its timing. Because the Bill was introduced ahead of a general election, its Select Committee process and further readings are expected to fall to the next Government, with full enactment anticipated in 2027 or 2028. This is reported to align loosely with New Zealand's next FATF mutual evaluation, expected in 2028, though no FATF primary-source confirmation of that date was located; the connection should be read as reported context rather than confirmed driver.

Outlook

Two questions will determine how quickly the picture firms up. The first is procedural: whether the Omnibus Bill is referred to a Select Committee before or after the general election, which will affect how much substantive work on the Bill's text occurs before a new Government takes carriage of it. The second is fiscal: whether DIA confirms commencement of the AML/CFT supervisory levy, which remains subject to separate Cabinet approval notwithstanding that the supervisory consolidation it would help fund took effect on 1 July 2026. Reporting entities should expect the practical compliance runway for the Bill's mandatory/voluntary reporting group restructuring and its new targeted financial sanctions framework to extend well into 2027 at the earliest, materially longer than the Bill's introduction date alone would suggest.

18 Oct 2026 · fim-2026-10-18

AML/CTF Regime

New Zealand's AML/CFT architecture underwent a structural consolidation and now faces a further legislative rebalancing. The Department of Internal Affairs became the jurisdiction's sole AML/CFT supervisor from 1 July 2026, under the AML/CFT (Supervisor, Levy, and Other Matters) Amendment Act 2026, replacing the prior model that had split supervisory responsibility across DIA, the Financial Markets Authority and the Reserve Bank of New Zealand. This consolidation applies across banks, payment companies, crypto-asset operators, gambling operators and other reporting entities, centralising AML/CFT oversight under a single regulator rather than three sector-specific ones.

Building on that consolidation, the AML/CFT (Omnibus) Amendment Bill was introduced to Parliament on 1 September 2026 as the fourth and final phase of New Zealand's AML/CFT reform programme. As reported, the Bill would give reporting entities greater flexibility on risk-based customer due diligence, create mandatory reporting groups with a lead entity, strengthen the Financial Intelligence Unit's and DIA's enforcement and account-freezing powers, double the maximum money-laundering sentence from 7 to 14 years, introduce an infringement-offence regime, and embed a new "specified sanction" concept that would integrate targeted financial sanctions compliance directly into the AML/CFT framework. For gambling operators specifically, the specified-sanction concept would create a more explicit sanctions-screening obligation than exists under the current framework.

Against this reform backdrop, New Zealand's FATF standing remains stable: the jurisdiction is assessed compliant on 9 Recommendations, largely compliant on 25, and partially compliant on 6, with no grey-listing or black-listing signal, and a fifth-round mutual evaluation still pending. New Zealand sits outside the European Economic Area and carries no transposition obligation under the EU AML Package.

Outlook

The Omnibus Bill's progress through Parliament is the key development to track. As at 18 October 2026 it had been introduced but not enacted, and its primary legislative text and select-committee status were not independently confirmed this cycle. If enacted as reported, it would materially rebalance the current more prescriptive customer due diligence model toward risk-based flexibility, while simultaneously strengthening enforcement powers and embedding sanctions screening across the AML/CFT regime -- a combination that increases compliance obligations in some respects (sanctions screening, mandatory reporting groups) while easing them in others (risk-based CDD discretion).

12 Oct 2026 · fim-2026-10-12

AML/CTF Regime

New Zealand's AML/CTF regime underwent a genuine structural change this cycle on the supervisory side, even as its legislative reform programme stalled. The Department of Internal Affairs became the sole AML/CFT supervisor from 1 July 2026, under the Anti-Money Laundering and Countering Financing of Terrorism (Supervisor, Levy, and Other Matters) Amendment Act 2026, replacing the prior three-supervisor model that had split oversight between DIA, the Reserve Bank of New Zealand, and the Financial Markets Authority. This is an architecture-level change: consolidating supervision into a single authority alters the lines of accountability and examination practice for every obliged entity in New Zealand, regardless of sector, and is the kind of structural shift that outweighs any single enforcement action in significance.

Against that consolidation, the legislative reform track has lost momentum. The AML/CFT (Omnibus) Amendment Bill, introduced on 1 September 2026 as the final stage of New Zealand's broader AML/CFT reform, was still before Parliament when Parliament was dissolved on 1 October 2026 ahead of the 7 November 2026 general election. The Bill would, if enacted, introduce risk-based simplified customer due diligence for low-risk relationships, repeal the existing section 33(3A) reliance-letter safe harbour, replace designated business groups with a mandatory/voluntary reporting-group structure, establish New Zealand's first standalone targeted-financial-sanctions legal framework, and strengthen Financial Intelligence Unit powers including temporary account-freezing authority. None of that is now guaranteed; enactment depends on the next Parliament taking the Bill up, and industry commentary has already flagged that the repeal of the existing reliance-letter safe harbour would be received as a partial offset against the simplified-CDD relief the reform was meant to deliver, not a pure net gain for obliged entities.

This is not the first relief delivered in 2026. The AML/CFT Amendment Act 2026 came into force on 19 May 2026, delivering customer due diligence and risk-assessment relief ahead of the stalled Omnibus Bill's final stage, so firms have already absorbed one tranche of change this year even as the larger package remains suspended. Separately, legal commentary places New Zealand's next FATF mutual evaluation at around 2028, though this is the commentators' own forward expectation rather than a FATF-confirmed date, and should not be treated as a fixed compliance deadline.

Outlook

The structural question for New Zealand's AML/CFT regime is whether the next government, formed after the 7 November 2026 election, picks up the Omnibus Bill substantially as drafted, amends it, or lets it lapse. DIA's sole-supervisor status is now settled and is unlikely to be reversed regardless of the election outcome, giving obliged entities a stable point of contact even while the legislative substance of CDD simplification, the new sanctions framework, and expanded FIU powers remain suspended. Firms should treat the 19 May 2026 and 1 July 2026 changes as the current, operative baseline, and the Omnibus Bill's further provisions as contingent on a political process that has not yet concluded.

D8 Commercial Activity

no_change

No NZ-specific financial-integrity-sector commercial event identified this cycle.

Regulatory horizon
Proposed2027 · ±multi_year

New Zealand beneficial-ownership register (companies and limited partnerships)

A future central register would require companies/limited partnerships to identify and disclose beneficial owners, with some fields made public.
source not collected
Proposed2027-Q1 · ±year

Further AML/CFT Act amendment Bill signalled

The Government has signalled intent to introduce a further Bill amending the AML/CFT Act in the current parliamentary term, following the 2026 supervisory and definitional amendments.
Proposed2027-Q3 · ±year

AML/CFT (Omnibus) Amendment Bill 2026

If enacted: risk-based simplified CDD for low-risk relationships; repeal of the s.33(3A) reliance-letter safe harbour; replacement of designated business groups with mandatory/voluntary reporting groups; a targeted-financial-sanctions legal framework; strengthened FIU powers including temporary account freezing; a regulation-making power for cash-payment restrictions on remittance/virtual-asset transfers.
3 dated · 3 pending date · baseline financial-integrity-2026-07-05
Role action cards
MLRO

A second bank-level AML/CFT civil penalty in under five months confirms DIA is actively enforcing transaction-monitoring and record-keeping standards under its new sole-supervisor role.

The Co-operative Bank penalty turns on control-design failures, not a missed illicit flow, which means monitoring-rule adequacy and assurance-testing documentation are squarely within DIA's current enforcement focus.

2 evidence refs
Compliance

DIA's consolidated supervisory authority, effective 1 July 2026, has carried enforcement momentum through from the prior three-regulator model without interruption.

Reporting entities previously supervised by RBNZ or the Financial Markets Authority now answer to DIA alone, and the Co-operative Bank case shows that transition has not reduced enforcement activity.

2 evidence refs
Legal

A consent-basis NZ$1.425 million civil penalty against The Co-operative Bank, with no laundering alleged, illustrates the civil-penalty exposure available to DIA under the AML/CFT Act 2009.

The penalty was agreed rather than contested, suggesting the evidentiary position on control deficiencies was not considered defensible; this is relevant to how similar exposures might be assessed and negotiated.

1 evidence refs
Board

A second bank AML/CFT court penalty within five months represents a material reputational and financial exposure pattern in the sector.

The scale of the penalty relative to disclosed financial metrics, alongside the recency of a comparable case at another bank, signals that AML/CFT control adequacy is now a recurring sector-wide governance concern under active supervision.

1 evidence refs
Risk

Two concluded bank AML/CFT civil penalties within five months, under a newly consolidated supervisor, indicate a sustained enforcement risk concentration in the banking sector.

The pattern suggests DIA's enforcement posture carried through the supervisory handover without a transitional lull, which is relevant to how enforcement-risk exposure is modelled for reporting entities going forward.

2 evidence refs
Operations

The penalty basis centres on transaction-monitoring rule design and assurance-testing adequacy, not case-level screening failures.

The findings point to systemic, rule-configuration-level gaps in monitoring and testing rather than isolated operational misses, relevant to how monitoring workflows are periodically assured.

1 evidence refs
Audit

The penalty finding explicitly cites inadequate assurance testing of monitoring systems as a core deficiency.

This directly implicates the documented evidence trail around periodic control testing, which is relevant to assessing whether current assurance-testing scope and documentation would withstand similar scrutiny.

1 evidence refs
Standing trackers (T1–T6)
TrackerStatusNote
T1 · Russian Sanctions-Evasion Architecturestable
T2 · EU AML Package / AMLAstableNot applicable to NZ, outside EEA/EU AMLR-6AMLD-AMLA perimeter.
T3 · FATF Grey ListstableNZ remains outside FATF grey/black list.
T4 · Beneficial-Ownership Register Statusstable
T5 · Crypto & Digital-Asset IntegritystableStanding CARF (1 Apr 2026) and DIA sole-supervisor (1 Jul 2026) positions unchanged.
T6 · Sanctions Regime Divergencestable
Registers

Enforcement actions

  • 20 Oct 2025
  • 31 Oct 2025
  • 17 Oct 2025
  • 19 Jun 2025
  • 1 Sep 2024
  • 28 Oct 2026
  • FATF's 3rd Enhanced Follow-Up Report re-rated New Zealand on five Recommendations (14, 16, 19, 22, 23) covering money/value transfer services, wire transfers, non-profit organisations, DNFBP customer due diligence and DNFBP other measures, reflecting legislative and supervisory reforms implemented since the 2021 mutual evaluation and 2022 follow-up. 18 Jul 2024
  • A sustained nationwide New Zealand Police operation against gang-linked organised crime resulted in more than 50,000 charges over roughly a year, including money-laundering, drug-trafficking and firearms offences, alongside asset seizures and restraint actions targeting proceeds of methamphetamine-driven organised crime. 7 Sep 2023
  • FATF's 2nd (2022) Follow-Up Report re-rated New Zealand's Recommendation 25 (transparency and beneficial ownership of legal arrangements) from partially compliant to largely compliant, reflecting trust-disclosure reforms introduced after the Panama and Pandora Papers investigations. 31 May 2022

Sanctions changes

  • New Zealand enacted the Russia Sanctions Act 2022, its first-ever standalone autonomous sanctions statute, in direct response to the invasion of Ukraine, enabling asset freezes, travel bans and prohibitions on evasion of allied sanctions — a structural departure from NZ's prior reliance on UN Security Council-derived sanctions only. 9 Mar 2022
  • New Zealand's Russia sanctions regime continues to diverge structurally from the EU/OFAC/OFSI architecture: it lacks equivalent sectoral directives (e.g. financial-services, energy, shadow-fleet vessel designations), secondary-sanctions exposure mechanisms, and a comparable volume of individual/entity listings, relying instead on close policy alignment with Five Eyes and EU partners with a lag in adopting equivalent designations. 1 Jun 2026

Regulatory horizon (register)

  • Next National Risk Assessment refresh cycles (UK NRA, EU SNRA)
  • AML/CFT (Omnibus) Amendment Bill
  • UK ECCTA 2023 failure-to-prevent-fraud offence
  • Next National Risk Assessment refresh cycles (UK NRA, EU SNRA)
  • New Zealand beneficial-ownership register (companies and limited partnerships)
  • Further AML/CFT Act amendment Bill signalled
  • AML/CFT (Omnibus) Amendment Bill 2026
  • AML/CFT (Omnibus) Amendment Bill
  • AML/CTF Omnibus Amendment Bill
  • New Zealand's 5th-round FATF mutual evaluation scheduling
  • Full beneficial ownership register implementation
  • Domestic alignment with FATF's 2025 Recommendation 1 proportionality changes

Active schemes

  • Foreign trust and TCSP structuring for offshore wealth concealment
  • [HIGH] Real estate and professional-services laundering channel
  • MVTS remittance-hub exploitation for Pacific-region crime
  • Crypto-to-fiat transit exposure via NZ-linked VASP activity
  • Low assessed CTF risk offset by targeted-sanctions implementation gap
Sources
  1. New Zealand Department of Internal Affairs
  2. New Zealand Ministry of Justice
  3. MinterEllisonRuddWatts
  4. Buddle Findlay
  5. IFC Review
  6. Tookitaki
  7. Casino Guardian
  8. FATF
  9. AMLUAE
  10. New Zealand Department of Internal Affairs
  11. Yogonet International (reporting Amnesty International findings)
  12. Cambodge Mag
  13. The Diplomat
  14. ProPublica
  15. FATF
  16. New Zealand Department of Internal Affairs
  17. https://www.rbnz.govt.nz/regulation-and-supervision/anti-money-laundering-and-countering-terrorism-financing
  18. https://www.dia.govt.nz/AML-CFT-News
  19. https://www.mfat.govt.nz/en/countries-and-regions/europe/ukraine/russian-invasion-of-ukraine/sanctions/overview-of-sanctions-against-russia
  20. https://www.thelawyermag.com/nz/news/general/government-eschews-crypto-ban-amlcft-omnibus-amendment-bill-to-be-introduced-to-set-limits/581965
  21. https://www.fma.govt.nz/news/all-releases/media-releases/fma-expands-sandbox/
  22. https://www.dpa.co.nz/blog/new-crypto-reporting-rules-are-coming-to-new-zealand/
  23. https://www.mbie.govt.nz/business-and-employment/consumer-protection/combatting-online-financial-scams
  24. https://agbrief.com/news/27/01/2026/cambodia-aims-to-avoid-fatf-grey-listing/
  25. https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html
  26. https://www.dia.govt.nz/New-Era-for-AML-CFT-regulation-as-DIA-Launches-Comprehensive-Guidance-Suite
  27. https://minterellison.co.nz/insights/dia-revises-aml-cft-guidance-signalling-a-new-approach-to-aml-cft-enforcement
  28. https://www.transparency.org.nz/blog/progress-on-beneficial-ownership-a-step-forward-but-a-long-road-remains
  29. https://www.fatf-gafi.org/en/countries/detail/New-Zealand.html
  30. https://www.fma.govt.nz/business/services/cryptocurrencies/
  31. https://www.fma.govt.nz/business/legislation/secondary-legislation/designations/financial-markets-conduct-ecdd-holdings-limited-stablecoin-designation-notice-2026/
  32. https://www.dentons.co.nz/en/insights/articles/2026/september/16/be-careful-what-you-wish-for-the-amlcft-omnibus-amendment-bill
  33. https://www.simpsongrierson.com/insights-news/legal-updates/aml-omnibus-reform-lifting-or-shifting-the-burden
  34. https://www.russellmcveagh.com/insights-news/amlcft-reform-final-bill-introduced-and-confirmation-of-expiry-of-managing-intermediaries-exemption/
  35. https://www.beehive.govt.nz/release/laws-passed-deliver-aml-red-tape-relief
  36. https://www.vitallaw.com/news/new-zealand-to-table-final-bill-overhauling-aml-cft-regime/gdn01174418
  37. https://minterellison.co.nz/insights/aml-cft-new-rules-new-regulator-new-reality
  38. New Zealand Government (Beehive)
  39. Dentons NZ
  40. Russell McVeagh
  41. Chambers Practice Guides
  42. NZ Parliamentary Counsel Office
  43. Dentons New Zealand
  44. MinterEllisonRuddWatts
  45. Legal 500 / KordaMentha
  46. NZ Ministry of Justice
  47. MinterEllisonRuddWatts
  48. Department of Internal Affairs
  49. Department of Internal Affairs
  50. interest.co.nz
  51. newswire.co.nz
  52. russellmcveagh.com
  53. legal500.com
  54. https://www.dia.govt.nz/AML-CFT-Homepage
  55. https://www.scoop.co.nz/stories/AK2610/S00812/high-court-decision-reinforces-importance-of-amlcft-compliance.htm
  56. https://www.interest.co.nz/banking/140882/co-operative-bank-penalised-nearly-three-times-half-year-profit-anti-money
  57. https://www.legal500.com/intelligence/new-zealand/corporate-commercial-law/amlcft-reforms-in-new-zealand-regulatory-change-and-dia-guidance-updates
  58. Mutual Evaluations
  59. Assessments
  60. New Zealand
  61. Consolidated assessment ratings
  62. Mutual Evaluation of New Zealand
  63. Asia/Pacific Group on Money Laundering (APG)
  64. Publications
  65. New Zealand's progress in strengthening measures to tackle money laundering and terrorist financing
  66. Consolidated Processes and Procedures for Mutual Evaluations and Follow-Up Universal Procedures
  67. 2022 Procedures for the FATF AML/CFT/CPF Mutual Evaluations, Follow-Up and ICRG
  68. November 2021 F o l l o w - u p r e p o r t Anti-money laundering and
  69. April 2021 Anti-money laundering and counter-terrorist financing measures
  70. New Zealand's measures to combat money laundering and terrorist financing
  71. ASIA-PACIFIC GROUP ON MONEY LAUNDERING FINANCIAL ACTION TASK FORCE
  72. The FATF Recommendations
  73. National risk assessment of money laundering and terrorist financing 2020 - GOV.UK
  74. UK national risk assessment of money laundering and terrorist financing - GOV.UK
  75. PPSI-AMLCFT-NPRM.pdf
  76. April 2021 Anti-money laundering and counter-terrorist financing measures
  77. New Zealand's measures to combat money laundering and terrorist financing
  78. FATF Guidance: Politically Exposed Persons (Recommendations 12 and 22)
  79. Home
  80. 1 Red ALERT Shadow Fleet Sanctions Evasion and Avoidance Network
  81. EU sanctions against Russia: questions and answers - Consilium
  82. Updated Price Cap Coalition Advisory for the Maritime Oil ...
  83. New Zealand to Introduce Further Sanctions on Russia | OCCRP
  84. Russian Tankers Go Dark Out at Sea to Circumvent Sanctions | OCCRP
  85. Russian Harmful Foreign Activities Sanctions | Office of Foreign Assets Control
  86. Russia's war of aggression against Ukraine: Council sanctions 41 vessels of the Russian shadow fleet - Consilium
  87. UK cracks down on backdoor Russian sanctions evasion with tough new measures - GOV.UK
  88. Russian Tankers Going Dark Raises Flags on Sanctions Evasion - Bloomberg
  89. FATF publishes new Guidance on Financial Inclusion and Anti-Money Laundering and Terrorist Financing Measures
  90. FinCEN Issues Final Rule to Postpone Effective Date of Investment Adviser Rule to 2028 | FinCEN.gov
  91. FinCEN Issues Proposed Rule to Postpone Effective Date of Investment Adviser Rule | FinCEN.gov
  92. New Zealand moves to crack down on corporate secrecy after Pandora Papers - ICIJ
  93. NEW ZEALAND SOCIETY overview - Companies House
  94. Guidance on Beneficial Ownership and Transparency of Legal Arrangements
  95. THE SOVEREIGN IN RIGHT OF NEW ZEALAND ACTING BY AND THROUGH THE SECRETARY OF FOREIGN AFFAIRS AND TRADE overview - Find and update company information - GOV.UK
  96. U.S. Beneficial Ownership Information Registry Now Accepting Reports | FinCEN.gov
  97. Guidance on Beneficial Ownership of Legal Persons
  98. FinCEN Removes Beneficial Ownership Reporting Requirements for U.S. Companies and U.S. Persons, Sets New Deadlines for Foreign Companies | FinCEN.gov
  99. Frequently Asked Questions | FinCEN.gov
  100. Beneficial Ownership Information Reporting Rule Fact Sheet | FinCEN.gov
  101. Vulnerabilities of Casinos and Gaming Sector
  102. FATF Guidance on the Risk-Based Approach for Casinos
  103. April 2021 Anti-money laundering and counter-terrorist financing measures
  104. SKC: SKYCITY Entertainment Group Ltd Stock Price Quote - NZX - Bloomberg
  105. SkyCity Gains From High Rollers as Gambling Scam Leaves Debt - Bloomberg
  106. Notices and updates
  107. 2026 Crypto Crime Report – Illicit Crypto Trends & Typologies | TRM Labs
  108. 2025 Crypto Regulatory Round-Up
  109. Crypto giants moved billions linked to money launderers, drug traffickers and North Korean hackers
  110. About The Coin Laundry global crypto investigation
  111. From Dubai to Toronto, inside the crypto-to-cash storefronts fueling money laundering’s new frontier
  112. New Zealand's progress in strengthening measures to tackle money laundering and terrorist financing
  113. New Zealand Freezes Funds of Russian Bitcoin Fraud Suspect | OCCRP
  114. 2025 Crypto Crime Mid-Year Update - Chainalysis
  115. 2026 Crypto Crime Report: Scams
  116. Money laundering
  117. Public Consultation on AML/CFT and Financial Inclusion - Updated FATF Guidance on AML/CFT Measures and Financial Inclusion
  118. FATF updates Standards and consults on guidance to better promote financial inclusion
  119. Public Consultation on AML/CFT and Financial Inclusion – proposed changes to FATF Standards
  120. Financial Inclusion and Anti-Money Laundering and Terrorist Financing Measures
  121. Sanctions Programs and Country Information | Office of Foreign Assets Control
  122. Recent Actions | Office of Foreign Assets Control
  123. Russia-related Sanctions Programs | Office of Foreign Assets Control
  124. United Nations Security Council Consolidated List | Security Council
  125. New Zealand to Introduce Further Sanctions on Russia | OCCRP
  126. Russian Harmful Foreign Activities Sanctions
  127. The UK Sanctions List - GOV.UK
  128. Russia-related Designations, Updates and Removal; Counter Terrorism Designation Update; Issuance of Russia-related General Licenses | Office of Foreign Assets Control
  129. "Black and grey" lists
  130. Jurisdictions under Increased Monitoring - 19 June 2026
  131. Jurisdictions under Increased Monitoring - 13 February 2026
  132. Outcomes FATF Plenary, 17-19 June 2026
  133. Money Laundering Advisory Notice: June 2026 - GOV.UK
  134. High-Risk Jurisdictions subject to a Call for Action - 19 June 2026
  135. News
  136. High-risk and other monitored jurisdictions
  137. Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov
  138. Jurisdictions under Increased Monitoring - 13 June 2025
  139. FATF GUIDANCE Money Laundering National Risk Assessment Guidance November 2024
  140. FATF launches National Risk Assessment toolkit to help countries identify greatest money laundering risks
  141. Public consultation on FATF Money Laundering National Risk Assessment Guidance Update
  142. Money Laundering National Risk Assessment Guidance
  143. FATF GUIDANCE Money Laundering National Risk Assessment Guidance
  144. Overseas business risk: New Zealand - GOV.UK
  145. Ukraine-/Russia-related Sanctions | Office of Foreign Assets Control
  146. Cyber-related Designations; CAATSA - Russia-related Designations; Russia-related Designation Update and Removal | Office of Foreign Assets Control
  147. Russia-related Designations; Issuance of New and Amended Russia-related General Licenses | Office of Foreign Assets Control
  148. Russia-related Designations; Issuance of Russia-related General Licenses and new and amended Frequently Asked Questions | Office of Foreign Assets Control
  149. New Zealand Department of Internal Affairs - Company Profile and News - Bloomberg Markets
  150. FATF Glossary
  151. 1 FIN-2024-FCT1 June 28, 2024
  152. Fact Sheet: Proposed Rule to Implement the GENIUS Act’s Anti-
  153. Revised Guidance on AML/CFT and Financial Inclusion
  154. TRANSNATIONAL ORGANISED CRIME IN NEW ZEALAND: OUR STRATEGY 2020–2025
  155. New Zealand Files 50,000 Charges in National Crackdown on Gangs | OCCRP
  156. New Zealand Cracks Down on Violent Biker Gang | OCCRP
  157. New Zealand Transnational Organized Crime Strategy for 2020-2025
  158. FATF REPORT Professional Money Laundering July 2018
  159. FATF, Egmont Group, INTERPOL and UNODC call for stronger co-operation between countries as they launch handbook to fight money laundering
  160. Ten years after the Panama Papers, enablers and tax cheats are still being brought to justice - ICIJ
  161. FATF / Asia-Pacific Group on Money Laundering
  162. FATF
  163. FATF
  164. ICIJ
  165. ICIJ
  166. OCCRP
  167. New Zealand Police (hosted via UNODC SHERLOC)
  168. OCCRP
Coverage gaps
fim-int-2026-07-11-G001: No fresh AMLR/6AMLD-transposition o…
fim-int-2026-07-11-G001: No fresh AMLR/6AMLD-transposition or AMLA-supervisory-perimeter movement was actively verified this cycle; search effort concentrated on NZ. [resolved]
fim-int-2026-07-11-G002: No material signal located for Mexi…
fim-int-2026-07-11-G002: No material signal located for Mexico or Colombia casino-based TBML corridors this cycle despite Tier-D coverage check. [resolved]
fim-int-2026-07-11-G003: No Tier-1/2 primary regulator sourc…
fim-int-2026-07-11-G003: No Tier-1/2 primary regulator source located corroborating Amnesty International's Cambodia casino-trafficking findings. [resolved]
fim-int-2026-07-11-G004: No NZ-specific RegTech/AI-transacti…
fim-int-2026-07-11-G004: No NZ-specific RegTech/AI-transaction-monitoring supervisory development (D6) was located this cycle. [resolved]
fim-int-2026-07-11-G005: DIA's own primary disclosure underl…
fim-int-2026-07-11-G005: DIA's own primary disclosure underlying the NZ$1.36bn offshore-spend figure was not directly located; relying on Tier-3 secondary characterisation. [resolved]
fim-int-2026-08-05-G001: Mexico and Colombia Tier-D watch ve…
fim-int-2026-08-05-G001: Mexico and Colombia Tier-D watch vectors were not actively resolved this cycle; research scope was bound to New Zealand. [resolved]
fim-int-2026-08-05-G002: sanctions_changes[].issuing_body cl…
fim-int-2026-08-05-G002: sanctions_changes[].issuing_body closed enum (OFAC|OFSI|EU_Council|UN) does not cover New Zealand's autonomous MFAT-administered sanctions programme; the underlying facts are captured in structured_claims fim-2026-W32-004 and domain D1 instead. [resolved]
fim-int-2026-08-05-G003: D2 and D4 domains had thin coverage…
fim-int-2026-08-05-G003: D2 and D4 domains had thin coverage this cycle; no NZ-specific beneficial-ownership legislative development or conflict-finance case was located beyond the cross-referenced Russia oil-price-cap tightening. [resolved]
fim-int-2026-08-05-G004: No ratified typology library (senti…
fim-int-2026-08-05-G004: No ratified typology library (sentinel-typology-library-v1.0.json) was supplied in context this cycle; typology_observations[] could not be populated against ratified fim-typ-NNN ids. [resolved]
fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', '…
fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): Primary instrument text of the AML/CFT (Supervisor, Levy, and Other Matters) Amendment Act 2026 was not directly retrieved; reliance is on primary DIA/FMA announcements and T3 law-firm summaries. [resolved]
fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', '…
fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', 'value': 'D2'}): No primary Cabinet paper or Bill text on the proposed beneficial-ownership register was retrieved this cycle; reliance is on NGO and press coverage of a Ministerial announcement. [resolved]
fim-int-2026-09-28-G003: D1 (sanctions), D3 (enabler jurisdi…
fim-int-2026-09-28-G003: D1 (sanctions), D3 (enabler jurisdictions), D4 (conflict finance) and D6 (compliance technology) carried no NZ-specific finding this cycle; coverage was thin across these domains. [resolved]
fim-int-2026-10-12-G001 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-12-G001 ({'scheme': 'financial_integrity', 'value': 'D8'}): No New Zealand-specific D8 commercial-activity (M&A, investment, divestiture) finding relevant to financial-integrity infrastructure firms was located this cycle. [resolved]
fim-int-2026-10-12-G002 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-12-G002 ({'scheme': 'financial_integrity', 'value': 'D2'}): No New Zealand beneficial-ownership register development was located this cycle. [resolved]
fim-int-2026-10-12-G003 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-12-G003 ({'scheme': 'financial_integrity', 'value': 'D3'}): No New Zealand-specific enabler-jurisdiction finding was located this cycle. [resolved]
fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', 'value': 'D2'}): No New Zealand-specific beneficial-ownership register development was located this cycle; D2/D3/D4 coverage remains thin for this jurisdiction. [resolved]
fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', 'value': 'D7'}): The AML/CFT (Omnibus) Amendment Bill's primary legislative text and select-committee status at the exact cycle date were not independently retrieved. [resolved]
fim-int-2026-10-18-G003 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-18-G003 ({'scheme': 'financial_integrity', 'value': 'D5'}): The FMA's own NZDD designation notice text was not independently retrieved this cycle; reliance is on secondary/tertiary reporting. [resolved]
fim-int-2026-10-25-G001: D1, D3, D4, D5, D6 Tier-1 New Zeala…
fim-int-2026-10-25-G001: D1, D3, D4, D5, D6 Tier-1 New Zealand-specific findings were thin this cycle; this run was bound to NZ only and the broader cross-jurisdictional sweep was not performed. [resolved]
fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', 'value': 'D7'}): Whether the Omnibus Bill is formally referred to a Select Committee before or after the general election is not yet established. [resolved]
fim-int-2026-10-25-G003 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-25-G003 ({'scheme': 'financial_integrity', 'value': 'D7'}): Whether DIA has confirmed commencement of the AML/CFT supervisory levy (subject to separate Cabinet approval) was not established this cycle. [resolved]
fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', '…
fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): T1 pinpoint provision for the transitional/good-faith period in the AML/CFT Omnibus Bill was not independently retrieved this cycle; only T3 legal commentary available. [open]
fim-int-2026-11-01-G002 ({'scheme': 'financial_integrity', '…
fim-int-2026-11-01-G002 ({'scheme': 'financial_integrity', 'value': 'D1'}): D1-D5 returned thin or no NZ-specific coverage this cycle; no sourced finding of material change in sanctions, beneficial ownership, enabler-jurisdiction, conflict-finance, or crypto/digital-asset domains for NZ. [open]
FIM-GAP-001 (D1): New Zealand's 2021 MER found no assets had…
FIM-GAP-001 (D1): New Zealand's 2021 MER found no assets had ever been frozen under targeted financial sanctions (TFS) regimes; the 2024 Follow-Up Report continued to flag TFS implementation and supervision as an area requiring focus alongside beneficial ownership and general supervision improvements.
FIM-GAP-002 (D3): Public, internationally-indexed reporting …
FIM-GAP-002 (D3): Public, internationally-indexed reporting on granular New Zealand-domestic AML/CFT supervisory penalty or licence actions (FMA, DIA, RBNZ) within the strict 18-month baseline window (Jan 2025–Jul 2026) is sparse in Tier 1–2 sources; the most substantive verifiable enforcement-adjacent events located (FATF follow-up re-ratings, 2023 gang-crackdown reporting) sit at or just outside the window edge.
FIM-GAP-003 (D2): Despite the 2022 beneficial ownership regi…
FIM-GAP-003 (D2): Despite the 2022 beneficial ownership register bill and post-Panama Papers foreign trust disclosure reforms, New Zealand's legal framework still permits nominee director and nominee shareholder arrangements that can obscure ultimate beneficial ownership, a loophole explicitly identified in the 2021 MER as capable of undermining otherwise-improved BO measures.

Evidence

Confidence-tiered claims

Bill introduced 1 Sept 2026, Parliament dissolved 1 Oct 2026 ahead of 7 Nov 2026 election; enactment now falls to the next Government [Source 1]
Probable · 1 source
Government abandoned outright crypto-ATM ban in favour of targeted cash-payment restriction regulation-making power; consultation deferred to early 2027 [Source 1]
Probable · 1 source
2026-07-01 [Source 1]
Probable · 1 source
in force from 19 May 2026 [Source 1]
Probable · 1 source
around 2028 (commentary, not FATF-confirmed) [Source 1]
Probable · 1 source
Introduced 1 September 2026 as the fourth and final phase of New Zealand's AML/CFT reform programme [Source 1]
Probable · 1 source
DIA became New Zealand's sole AML/CFT supervisor from 1 July 2026, replacing the prior three-regulator (DIA/FMA/RBNZ) model [Source 1]
Probable · 1 source
FMA designation notice (reported 11 March 2026) declares NZDD is not a 'financial product' because it pays no interest and functions as a payment/remittance instrument [Source 1]
Probable · 1 source
Compliant on 9 Recommendations, largely compliant on 25, partially compliant on 6, pending fifth-round mutual evaluation [Source 1]
Probable · 1 source
Would give reporting entities more flexibility on risk-based CDD, create mandatory reporting groups, strengthen FIU/DIA enforcement and account-freezing powers, and embed a 'specified sanction' concept [Source 1]
Probable · 1 source
Introduced to Parliament 1 September 2026; described by the Associate Minister of Justice as the most substantial reform of the Act since 2009 [Source 1]
Probable · 1 source
DIA became New Zealand's sole AML/CFT supervisor from 1 July 2026, replacing the prior three-supervisor model (DIA/FMA/RBNZ) [Source 1]
Probable · 1 source
PEP identification continues to shift to a risk-based standard under the ongoing AML/CFT reform programme [Source 1]
Probable · 1 source
New Zealand's next FATF mutual evaluation is expected in 2028, noted as a driver for the Omnibus Bill's timing [Source 1]
Probable · 1 source
The Bill establishes, for the first time, a dedicated statutory framework for targeted financial sanctions within the AML/CFT Act structure [Source 1]
Probable · 1 source
1425000 [Source 1]
Probable · 1 source
NZ$1.425 million High Court-confirmed civil penalty for AML/CFT Act 2009 breaches (deficient transaction-monitoring rules, inadequate assurance testing, insufficient record-keeping) [Source 1]
Probable · 1 source
DIA became New Zealand's sole AML/CFT supervisor for all reporting entities from 1 July 2026, replacing the prior DIA/FMA/RBNZ three-supervisor model [Source 1]
Probable · 1 source
Introduced before Parliament's dissolution on 1 October 2026 ahead of the 7 November 2026 general election; further progress paused pending the election outcome [Source 1]
Probable · 1 source