--- title: "New Zealand (NZ) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/new-zealand/ source_html: /jurisdictions/new-zealand/index.html description: "Financial integrity intelligence for New Zealand (NZ): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T04:46:02Z content_sha256: bb956bf3388d87bdab15e84985363acea0bef5103d9a6697c607346db0695795 generator: "fe-fleet/md-twin@1.0" --- # New Zealand (NZ) — Financial-Integrity Intelligence · Sentinel 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). More Strong 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) #### 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. #### 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. #### 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. No NZ-specific conflict-finance development identified this cycle. #### 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. No NZ-specific RegTech/compliance-technology development identified this cycle. #### 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. No NZ-specific financial-integrity-sector commercial event identified this cycle. Regulatory horizon Proposed 2027 · ±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 Proposed 2027-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. [New Zealand Government Source](https://www.lawsociety.org.nz/news/publications/lawtalk/lawtalk-issue-965/amlcft-in-the-spotlight/) Proposed 2027-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. [New Zealand Parliament / Associate Minister of Justice Source](https://www.dentons.co.nz/en/insights/articles/2026/september/16/be-careful-what-you-wish-for-the-amlcft-omnibus-amendment-bill) 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) Tracker Status Note T1 · Russian Sanctions-Evasion Architecture stable T2 · EU AML Package / AMLA stable Not applicable to NZ, outside EEA/EU AMLR-6AMLD-AMLA perimeter. T3 · FATF Grey List stable NZ remains outside FATF grey/black list. T4 · Beneficial-Ownership Register Status stable T5 · Crypto & Digital-Asset Integrity stable Standing CARF (1 Apr 2026) and DIA sole-supervisor (1 Jul 2026) positions unchanged. T6 · Sanctions Regime Divergence stable 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 - [New Zealand Department of Internal Affairs](https://www.dia.govt.nz/AML-CFT-News) - [New Zealand Ministry of Justice](https://www.justice.govt.nz/justice-sector-policy/key-initiatives/aml-cft/) - [MinterEllisonRuddWatts](https://minterellison.co.nz/insights/aml-cft-new-rules-new-regulator-new-reality) - [Buddle Findlay](https://www.buddlefindlay.com/insights/amlcft-reform-significant-regulatory-and-structural-changes-to-amlcft/) - [IFC Review](https://www.ifcreview.com/articles/2026/july/new-zealand-developments-in-the-financial-services-regulatory-landscape/) - [Tookitaki](https://www.tookitaki.com/compliance-hub/aml-cft-compliance-new-zealand) - [Casino Guardian](https://www.casinoguardian.co.uk/2026/05/21/new-zealand-takes-first-steps-toward-regulating-a-billion-dollar-online-gambling-market/) - [FATF](https://www.fatf-gafi.org/en/countries/detail/New-Zealand.html) - [AMLUAE](https://amluae.com/fatf-grey-list-countries-update-19th-june-2026/) - [New Zealand Department of Internal Affairs](https://www.dia.govt.nz/AML-CFT-Jurisdictions-under-Increased-Monitoring---February-2026) - [Yogonet International (reporting Amnesty International findings)](https://www.yogonet.com/international/news/2026/04/06/118410-amnesty-international-says-licensed-cambodian-casinos-remain-tied-to-trafficking-and-torture) - [Cambodge Mag](https://www.cambodgemag.com/en/post/cambodia-s-invisible-scam-empire-raids-resilience-and-relentless-networks) - [The Diplomat](https://thediplomat.com/2025/07/fatf-is-behind-the-curve-on-cambodias-cyber-scam-compounds/) - [ProPublica](https://www.propublica.org/article/casinos-cambodia-myanmar-laos-southeast-asia-fraud-cybercrime) - [FATF](https://www.fatf-gafi.org/en/countries/detail/Lao-People-s-Democratic-Republic.html) - [New Zealand Department of Internal Affairs](https://www.dia.govt.nz/AML-CFT-Legislation) - [https://www.rbnz.govt.nz/regulation-and-supervision/anti-money-laundering-and-countering-terrorism-financing](https://www.rbnz.govt.nz/regulation-and-supervision/anti-money-laundering-and-countering-terrorism-financing) - [https://www.dia.govt.nz/AML-CFT-News](https://www.dia.govt.nz/AML-CFT-News) - [https://www.mfat.govt.nz/en/countries-and-regions/europe/ukraine/russian-invasion-of-ukraine/sanctions/overview-of-sanctions-against-russia](https://www.mfat.govt.nz/en/countries-and-regions/europe/ukraine/russian-invasion-of-ukraine/sanctions/overview-of-sanctions-against-russia) - [https://www.thelawyermag.com/nz/news/general/government-eschews-crypto-ban-amlcft-omnibus-amendment-bill-to-be-introduced-to-set-limits/581965](https://www.thelawyermag.com/nz/news/general/government-eschews-crypto-ban-amlcft-omnibus-amendment-bill-to-be-introduced-to-set-limits/581965) - [https://www.fma.govt.nz/news/all-releases/media-releases/fma-expands-sandbox/](https://www.fma.govt.nz/news/all-releases/media-releases/fma-expands-sandbox/) - [https://www.dpa.co.nz/blog/new-crypto-reporting-rules-are-coming-to-new-zealand/](https://www.dpa.co.nz/blog/new-crypto-reporting-rules-are-coming-to-new-zealand/) - [https://www.mbie.govt.nz/business-and-employment/consumer-protection/combatting-online-financial-scams](https://www.mbie.govt.nz/business-and-employment/consumer-protection/combatting-online-financial-scams) - [https://agbrief.com/news/27/01/2026/cambodia-aims-to-avoid-fatf-grey-listing/](https://agbrief.com/news/27/01/2026/cambodia-aims-to-avoid-fatf-grey-listing/) - [https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html) - [https://www.dia.govt.nz/New-Era-for-AML-CFT-regulation-as-DIA-Launches-Comprehensive-Guidance-Suite](https://www.dia.govt.nz/New-Era-for-AML-CFT-regulation-as-DIA-Launches-Comprehensive-Guidance-Suite) - [https://minterellison.co.nz/insights/dia-revises-aml-cft-guidance-signalling-a-new-approach-to-aml-cft-enforcement](https://minterellison.co.nz/insights/dia-revises-aml-cft-guidance-signalling-a-new-approach-to-aml-cft-enforcement) - [https://www.transparency.org.nz/blog/progress-on-beneficial-ownership-a-step-forward-but-a-long-road-remains](https://www.transparency.org.nz/blog/progress-on-beneficial-ownership-a-step-forward-but-a-long-road-remains) - [https://www.fatf-gafi.org/en/countries/detail/New-Zealand.html](https://www.fatf-gafi.org/en/countries/detail/New-Zealand.html) - [https://www.fma.govt.nz/business/services/cryptocurrencies/](https://www.fma.govt.nz/business/services/cryptocurrencies/) - [https://www.fma.govt.nz/business/legislation/secondary-legislation/designations/financial-markets-conduct-ecdd-holdings-limited-stablecoin-designation-notice-2026/](https://www.fma.govt.nz/business/legislation/secondary-legislation/designations/financial-markets-conduct-ecdd-holdings-limited-stablecoin-designation-notice-2026/) - [https://www.dentons.co.nz/en/insights/articles/2026/september/16/be-careful-what-you-wish-for-the-amlcft-omnibus-amendment-bill](https://www.dentons.co.nz/en/insights/articles/2026/september/16/be-careful-what-you-wish-for-the-amlcft-omnibus-amendment-bill) - [https://www.simpsongrierson.com/insights-news/legal-updates/aml-omnibus-reform-lifting-or-shifting-the-burden](https://www.simpsongrierson.com/insights-news/legal-updates/aml-omnibus-reform-lifting-or-shifting-the-burden) - [https://www.russellmcveagh.com/insights-news/amlcft-reform-final-bill-introduced-and-confirmation-of-expiry-of-managing-intermediaries-exemption/](https://www.russellmcveagh.com/insights-news/amlcft-reform-final-bill-introduced-and-confirmation-of-expiry-of-managing-intermediaries-exemption/) - [https://www.beehive.govt.nz/release/laws-passed-deliver-aml-red-tape-relief](https://www.beehive.govt.nz/release/laws-passed-deliver-aml-red-tape-relief) - [https://www.vitallaw.com/news/new-zealand-to-table-final-bill-overhauling-aml-cft-regime/gdn01174418](https://www.vitallaw.com/news/new-zealand-to-table-final-bill-overhauling-aml-cft-regime/gdn01174418) - [https://minterellison.co.nz/insights/aml-cft-new-rules-new-regulator-new-reality](https://minterellison.co.nz/insights/aml-cft-new-rules-new-regulator-new-reality) - [New Zealand Government (Beehive)](https://www.beehive.govt.nz/release/laws-passed-deliver-aml-red-tape-relief) - [Dentons NZ](https://www.dentons.co.nz/en/insights/articles/2026/september/16/be-careful-what-you-wish-for-the-amlcft-omnibus-amendment-bill) - [Russell McVeagh](https://www.russellmcveagh.com/insights-news/watching-brief-october-2026/) - [Chambers Practice Guides](https://practiceguides.chambers.com/practice-guides/blockchain-crypto-assets-2026/new-zealand) - [NZ Parliamentary Counsel Office](https://www.legislation.govt.nz/bill/government/2026/342/en/latest/) - [Dentons New Zealand](https://www.dentons.co.nz/en/insights/articles/2026/september/16/be-careful-what-you-wish-for-the-amlcft-omnibus-amendment-bill) - [MinterEllisonRuddWatts](https://minterellison.co.nz/insights/aml-cft-overhaul-final-amendment-bill-introduced-to-parliament) - [Legal 500 / KordaMentha](https://www.legal500.com/intelligence/new-zealand/corporate-commercial-law/amlcft-reforms-in-new-zealand-regulatory-change-and-dia-guidance-updates) - [NZ Ministry of Justice](https://www.justice.govt.nz/justice-sector-policy/key-initiatives/aml-cft/legislate-changes/) - [MinterEllisonRuddWatts](https://minterellison.co.nz/insights/aml-cft-amendment-bills-pass-final-reading-set-to) - [Department of Internal Affairs](https://www.dia.govt.nz/AML-CFT-Homepage) - [Department of Internal Affairs](https://www.scoop.co.nz/stories/AK2610/S00812/high-court-decision-reinforces-importance-of-amlcft-compliance.htm) - [interest.co.nz](https://www.interest.co.nz/banking/140882/co-operative-bank-penalised-nearly-three-times-half-year-profit-anti-money) - [newswire.co.nz](https://newswire.co.nz/2026/10/co-operative-bank-1-425-million-anti-money-laundering-penalty-high-court/) - [russellmcveagh.com](https://www.russellmcveagh.com/insights-news/amlcft-reform-final-bill-introduced-and-confirmation-of-expiry-of-managing-intermediaries-exemption/) - [legal500.com](https://www.legal500.com/intelligence/new-zealand/corporate-commercial-law/amlcft-reforms-in-new-zealand-regulatory-change-and-dia-guidance-updates) - [https://www.dia.govt.nz/AML-CFT-Homepage](https://www.dia.govt.nz/AML-CFT-Homepage) - [https://www.scoop.co.nz/stories/AK2610/S00812/high-court-decision-reinforces-importance-of-amlcft-compliance.htm](https://www.scoop.co.nz/stories/AK2610/S00812/high-court-decision-reinforces-importance-of-amlcft-compliance.htm) - [https://www.interest.co.nz/banking/140882/co-operative-bank-penalised-nearly-three-times-half-year-profit-anti-money](https://www.interest.co.nz/banking/140882/co-operative-bank-penalised-nearly-three-times-half-year-profit-anti-money) - [https://www.legal500.com/intelligence/new-zealand/corporate-commercial-law/amlcft-reforms-in-new-zealand-regulatory-change-and-dia-guidance-updates](https://www.legal500.com/intelligence/new-zealand/corporate-commercial-law/amlcft-reforms-in-new-zealand-regulatory-change-and-dia-guidance-updates) - [Mutual Evaluations](https://www.fatf-gafi.org/en/topics/mutual-evaluations.html) - [Assessments](https://www.fatf-gafi.org/en/calendars/assessments.html) - [New Zealand](https://www.fatf-gafi.org/en/countries/detail/New-Zealand.html) - [Consolidated assessment ratings](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Assessment-ratings.html) - [Mutual Evaluation of New Zealand](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationofnewzealand.html) - [Asia/Pacific Group on Money Laundering (APG)](https://www.fatf-gafi.org/en/countries/global-network/asia-pacific-group-on-money-laundering--apg-.html) - [Publications](https://www.fatf-gafi.org/en/publications.html) - [New Zealand's progress in strengthening measures to tackle money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/New-Zealand-FUR-2024.html) - [Consolidated Processes and Procedures for Mutual Evaluations and Follow-Up Universal Procedures](https://www.fatf-gafi.org/en/publications/Fatfgeneral/Universal-procedures.html) - [2022 Procedures for the FATF AML/CFT/CPF Mutual Evaluations, Follow-Up and ICRG](https://www.fatf-gafi.org/en/publications/Mutualevaluations/5th-Round-Procedures.html) - [November 2021 F o l l o w - u p r e p o r t Anti-money laundering and](https://www.fatf-gafi.org/content/dam/fatf-gafi/fur/New-Zealand-2024-FUR.pdf.coredownload.inline.pdf) - [April 2021 Anti-money laundering and counter-terrorist financing measures](https://www.fatf-gafi.org/content/dam/fatf-gafi/mer/Mutual-Evaluation-Report-New-Zealand-2021.pdf) - [New Zealand's measures to combat money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mer-new-zealand-2021.html) - [ASIA-PACIFIC GROUP ON MONEY LAUNDERING FINANCIAL ACTION TASK FORCE](https://www.fatf-gafi.org/content/dam/fatf-gafi/mer/MER%20New%20Zealand%20ful.pdf.coredownload.pdf) - [The FATF Recommendations](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Fatf-recommendations.html) - [National risk assessment of money laundering and terrorist financing 2020 - GOV.UK](https://www.gov.uk/government/publications/national-risk-assessment-of-money-laundering-and-terrorist-financing-2020) - [UK national risk assessment of money laundering and terrorist financing - GOV.UK](https://www.gov.uk/government/publications/uk-national-risk-assessment-of-money-laundering-and-terrorist-financing) - [PPSI-AMLCFT-NPRM.pdf](https://www.fincen.gov/system/files/2026-04/PPSI-AMLCFT-NPRM.pdf) - [April 2021 Anti-money laundering and counter-terrorist financing measures](https://www.fatf-gafi.org/media/fatf/documents/reports/mer4/Mutual-Evaluation-Report-New-Zealand-2021.pdf) - [New Zealand's measures to combat money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/mutualevaluations/documents/mer-new-zealand-2021.html) - [FATF Guidance: Politically Exposed Persons (Recommendations 12 and 22)](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Peps-r12-r22.html) - [Home](https://www.fatf-gafi.org/en/home.html) - [1 Red ALERT Shadow Fleet Sanctions Evasion and Avoidance Network](https://www.nationalcrimeagency.gov.uk/who-we-are/publications/753-red-alert-shadow-fleet-sanctions-evasion-and-avoidance-network/file) - [EU sanctions against Russia: questions and answers - Consilium](https://www.consilium.europa.eu/en/policies/sanctions-against-russia-explained/) - [Updated Price Cap Coalition Advisory for the Maritime Oil ...](https://ofac.treasury.gov/media/933506/download?inline=) - [New Zealand to Introduce Further Sanctions on Russia | OCCRP](https://www.occrp.org/en/daily/16064-new-zealand-to-introduce-further-sanctions-on-russia) - [Russian Tankers Go Dark Out at Sea to Circumvent Sanctions | OCCRP](https://www.occrp.org/en/news/russian-tankers-go-dark-out-at-sea-to-circumvent-sanctions) - [Russian Harmful Foreign Activities Sanctions | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions) - [Russia's war of aggression against Ukraine: Council sanctions 41 vessels of the Russian shadow fleet - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2025/12/18/russia-s-war-of-aggression-against-ukraine-council-sanctions-41-vessels-of-the-russian-shadow-fleet/) - [UK cracks down on backdoor Russian sanctions evasion with tough new measures - GOV.UK](https://www.gov.uk/government/news/uk-cracks-down-on-backdoor-russian-sanctions-evasion-with-tough-new-measures) - [Russian Tankers Going Dark Raises Flags on Sanctions Evasion - Bloomberg](https://www.bloomberg.com/news/articles/2022-03-27/russian-tankers-going-dark-raises-flags-on-sanctions-evasion) - [FATF publishes new Guidance on Financial Inclusion and Anti-Money Laundering and Terrorist Financing Measures](https://www.fatf-gafi.org/en/publications/Financialinclusionandnpoissues/guidance-financial-inclusion-aml-tf-measures.html) - [FinCEN Issues Final Rule to Postpone Effective Date of Investment Adviser Rule to 2028 | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-issues-final-rule-postpone-effective-date-investment-adviser-rule-2028) - [FinCEN Issues Proposed Rule to Postpone Effective Date of Investment Adviser Rule | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-issues-proposed-rule-postpone-effective-date-investment-adviser-rule) - [New Zealand moves to crack down on corporate secrecy after Pandora Papers - ICIJ](https://www.icij.org/investigations/pandora-papers/new-zealand-moves-to-crack-down-on-corporate-secrecy-after-pandora-papers/) - [NEW ZEALAND SOCIETY overview - Companies House](https://find-and-update.company-information.service.gov.uk/company/05654421) - [Guidance on Beneficial Ownership and Transparency of Legal Arrangements](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-Beneficial-Ownership-Transparency-Legal-Arrangements.html) - [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](https://find-and-update.company-information.service.gov.uk/company/OE020656) - [U.S. Beneficial Ownership Information Registry Now Accepting Reports | FinCEN.gov](https://www.fincen.gov/news/news-releases/us-beneficial-ownership-information-registry-now-accepting-reports) - [Guidance on Beneficial Ownership of Legal Persons](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-Beneficial-Ownership-Legal-Persons.html) - [FinCEN Removes Beneficial Ownership Reporting Requirements for U.S. Companies and U.S. Persons, Sets New Deadlines for Foreign Companies | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-removes-beneficial-ownership-reporting-requirements-us-companies-and-us) - [Frequently Asked Questions | FinCEN.gov](https://www.fincen.gov/boi-faqs) - [Beneficial Ownership Information Reporting Rule Fact Sheet | FinCEN.gov](https://www.fincen.gov/beneficial-ownership-information-reporting-rule-fact-sheet) - [Vulnerabilities of Casinos and Gaming Sector](https://www.fatf-gafi.org/content/fatf-gafi/en/publications/Methodsandtrends/Vulnerabilitiesofcasinosandgamingsector.html) - [FATF Guidance on the Risk-Based Approach for Casinos](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Fatfguidanceontherisk-basedapproachforcasinos.html) - [April 2021 Anti-money laundering and counter-terrorist financing measures](https://fatf-gafi.org/media/fatf/documents/reports/mer4/Mutual-Evaluation-Report-New-Zealand-2021.pdf) - [SKC: SKYCITY Entertainment Group Ltd Stock Price Quote - NZX - Bloomberg](https://www.bloomberg.com/quote/SKC:NZ) - [SkyCity Gains From High Rollers as Gambling Scam Leaves Debt - Bloomberg](https://www.bloomberg.com/news/articles/2013-08-14/skycity-gains-from-high-rollers-in-auckland-as-scam-leaves-debt) - [Notices and updates](https://www.gamblingcommission.gov.uk/licensees-and-businesses/notices/aml) - [2026 Crypto Crime Report – Illicit Crypto Trends & Typologies | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/2026-crypto-crime-report) - [2025 Crypto Regulatory Round-Up](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/) - [Crypto giants moved billions linked to money launderers, drug traffickers and North Korean hackers](https://www.icij.org/investigations/coin-laundry/cryptocurrency-exchanges-binance-okx-money-laundering-crime/) - [About The Coin Laundry global crypto investigation](https://www.icij.org/investigations/coin-laundry/about-coin-laundry-investigation-cryptocurrency/) - [From Dubai to Toronto, inside the crypto-to-cash storefronts fueling money laundering’s new frontier](https://www.icij.org/investigations/coin-laundry/crypto-cash-desk-currency-exchange-money-laundering/) - [New Zealand's progress in strengthening measures to tackle money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Fur-new-zealand-2022.html) - [New Zealand Freezes Funds of Russian Bitcoin Fraud Suspect | OCCRP](https://www.occrp.org/en/news/new-zealand-freezes-funds-of-russian-bitcoin-fraud-suspect) - [2025 Crypto Crime Mid-Year Update - Chainalysis](https://www.chainalysis.com/blog/2025-crypto-crime-mid-year-update/) - [2026 Crypto Crime Report: Scams](https://www.chainalysis.com/blog/crypto-scams-2026/) - [Money laundering](https://www.trmlabs.com/glossary/money-laundering) - [Public Consultation on AML/CFT and Financial Inclusion - Updated FATF Guidance on AML/CFT Measures and Financial Inclusion](https://www.fatf-gafi.org/en/publications/Financialinclusionandnpoissues/aml-cft-financial-inclusion-public-consultation-february-2025.html) - [FATF updates Standards and consults on guidance to better promote financial inclusion](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/update-standards-promote-financial-conclusion-feb-2025.html) - [Public Consultation on AML/CFT and Financial Inclusion – proposed changes to FATF Standards](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/R1-INR1-INR10-INR15-Public-Consultation-Oct-24.html) - [Financial Inclusion and Anti-Money Laundering and Terrorist Financing Measures](https://www.fatf-gafi.org/content/dam/fatf-gafi/guidance/Guidance-Financial-Inclusion%20-Anti-Money-Laundering-Terrorist-Financing-Measures.pdf.coredownload.pdf) - [Sanctions Programs and Country Information | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information) - [Recent Actions | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions) - [Russia-related Sanctions Programs | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/russia-related-sanctions) - [United Nations Security Council Consolidated List | Security Council](https://main.un.org/securitycouncil/en/content/un-sc-consolidated-list) - [New Zealand to Introduce Further Sanctions on Russia | OCCRP](https://www.occrp.org/en/news/new-zealand-to-introduce-further-sanctions-on-russia) - [Russian Harmful Foreign Activities Sanctions](https://ofac.treasury.gov/faqs/topic/6626) - [The UK Sanctions List - GOV.UK](https://www.gov.uk/government/publications/the-uk-sanctions-list) - [Russia-related Designations, Updates and Removal; Counter Terrorism Designation Update; Issuance of Russia-related General Licenses | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20231102) - ["Black and grey" lists](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html) - [Jurisdictions under Increased Monitoring - 19 June 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [Jurisdictions under Increased Monitoring - 13 February 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html) - [Outcomes FATF Plenary, 17-19 June 2026](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-june-2026.html) - [Money Laundering Advisory Notice: June 2026 - GOV.UK](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2/money-laundering-advisory-notice-high-risk-third-countries--2) - [High-Risk Jurisdictions subject to a Call for Action - 19 June 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/call-for-action-june-2026.html) - [News](https://www.fatf-gafi.org/en/the-fatf/news.html) - [High-risk and other monitored jurisdictions](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions.html) - [Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov](https://www.fincen.gov/news/news-releases/financial-action-task-force-identifies-jurisdictions-anti-money-laundering-5) - [Jurisdictions under Increased Monitoring - 13 June 2025](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2025.html) - [FATF GUIDANCE Money Laundering National Risk Assessment Guidance November 2024](https://www.fatf-gafi.org/content/dam/fatf-gafi/reports/Money-Laundering-National-Risk-Assessment-Guidance-2024.pdf.coredownload.inline.pdf) - [FATF launches National Risk Assessment toolkit to help countries identify greatest money laundering risks](https://www.fatf-gafi.org/en/publications/Fatfgeneral/FATF-launches-National-Risk-Assessment-toolkit-to-help-countries-identify-greatest-money-laundering-risks.html) - [Public consultation on FATF Money Laundering National Risk Assessment Guidance Update](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/FATF-NRA-National-Risk-Assessments-Guidance-Public-Consultation-2024.html) - [Money Laundering National Risk Assessment Guidance](https://www.fatf-gafi.org/en/publications/Methodsandtrends/Money-Laundering-National-Risk-Assessment-Guidance.html) - [FATF GUIDANCE Money Laundering National Risk Assessment Guidance](https://www.fatf-gafi.org/content/dam/fatf-gafi/publications/Money%20Laundering%20National%20Risk%20Assessment%20Guidance.pdf.coredownload.inline.pdf) - [Overseas business risk: New Zealand - GOV.UK](https://www.gov.uk/government/publications/overseas-business-risk-new-zealand/overseas-business-risk-new-zealand) - [Ukraine-/Russia-related Sanctions | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/ukraine-russia-related-sanctions) - [Cyber-related Designations; CAATSA - Russia-related Designations; Russia-related Designation Update and Removal | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20250701) - [Russia-related Designations; Issuance of New and Amended Russia-related General Licenses | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20251022) - [Russia-related Designations; Issuance of Russia-related General Licenses and new and amended Frequently Asked Questions | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20240223) - [New Zealand Department of Internal Affairs - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/6910181Z:NZ) - [FATF Glossary](https://www.fatf-gafi.org/en/pages/fatf-glossary.html) - [1 FIN-2024-FCT1 June 28, 2024](https://www.fincen.gov/system/files/shared/Program-NPRM-FactSheet-508.pdf) - [Fact Sheet: Proposed Rule to Implement the GENIUS Act’s Anti-](https://www.fincen.gov/system/files/2026-04/FactSheet-PPSI-program-NPRM.pdf) - [Revised Guidance on AML/CFT and Financial Inclusion](https://www.fatf-gafi.org/en/publications/Financialinclusionandnpoissues/Revisedguidanceonamlcftandfinancialinclusion.html) - [TRANSNATIONAL ORGANISED CRIME IN NEW ZEALAND: OUR STRATEGY 2020–2025](https://sherloc.unodc.org/cld/uploads/res/treaties/strategies/new_zealand/nzl0003s_html/transnational-organised-crime-in-new-zealand-our-strategy-2020-to-2025.pdf) - [New Zealand Files 50,000 Charges in National Crackdown on Gangs | OCCRP](https://www.occrp.org/en/news/new-zealand-files-50000-charges-in-national-crackdown-on-gangs) - [New Zealand Cracks Down on Violent Biker Gang | OCCRP](https://www.occrp.org/en/news/new-zealand-cracks-down-on-violent-biker-gang) - [New Zealand Transnational Organized Crime Strategy for 2020-2025](https://www.unodc.org/cld/en/treaties/strategies/new_zealand/nzl0003s.html) - [FATF REPORT Professional Money Laundering July 2018](https://www.fatf-gafi.org/content/dam/fatf/documents/Professional-Money-Laundering.pdf) - [FATF, Egmont Group, INTERPOL and UNODC call for stronger co-operation between countries as they launch handbook to fight money laundering](https://www.fatf-gafi.org/en/publications/Methodsandtrends/international-cooperation-against-money-laundering.html) - [Ten years after the Panama Papers, enablers and tax cheats are still being brought to justice - ICIJ](https://www.icij.org/investigations/panama-papers/ten-years-after-the-panama-papers-enablers-and-tax-cheats-are-still-being-brought-to-justice/) - [FATF / Asia-Pacific Group on Money Laundering](https://www.fatf-gafi.org/content/dam/fatf-gafi/mer/Mutual-Evaluation-Report-New-Zealand-2021.pdf) - [FATF](https://www.fatf-gafi.org/en/publications/Mutualevaluations/New-Zealand-FUR-2024.html) - [FATF](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [ICIJ](https://www.icij.org/investigations/pandora-papers/new-zealand-moves-to-crack-down-on-corporate-secrecy-after-pandora-papers/) - [ICIJ](https://www.icij.org/investigations/panama-papers/ten-years-after-the-panama-papers-enablers-and-tax-cheats-are-still-being-brought-to-justice/) - [OCCRP](https://www.occrp.org/en/news/new-zealand-files-50000-charges-in-national-crackdown-on-gangs) - [New Zealand Police (hosted via UNODC SHERLOC)](https://sherloc.unodc.org/cld/uploads/res/treaties/strategies/new_zealand/nzl0003s_html/transnational-organised-crime-in-new-zealand-our-strategy-2020-to-2025.pdf) - [OCCRP](https://www.occrp.org/en/daily/16064-new-zealand-to-introduce-further-sanctions-on-russia) 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]](#sec-sources) 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]](#sec-sources) Probable · 1 source 2026-07-01 [[Source 1]](#sec-sources) Probable · 1 source in force from 19 May 2026 [[Source 1]](#sec-sources) Probable · 1 source around 2028 (commentary, not FATF-confirmed) [[Source 1]](#sec-sources) Probable · 1 source Introduced 1 September 2026 as the fourth and final phase of New Zealand's AML/CFT reform programme [[Source 1]](#sec-sources) 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]](#sec-sources) 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]](#sec-sources) Probable · 1 source Compliant on 9 Recommendations, largely compliant on 25, partially compliant on 6, pending fifth-round mutual evaluation [[Source 1]](#sec-sources) 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]](#sec-sources) 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]](#sec-sources) 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]](#sec-sources) Probable · 1 source PEP identification continues to shift to a risk-based standard under the ongoing AML/CFT reform programme [[Source 1]](#sec-sources) 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]](#sec-sources) 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]](#sec-sources) Probable · 1 source 1425000 [[Source 1]](#sec-sources) 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]](#sec-sources) 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]](#sec-sources) 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]](#sec-sources) Probable · 1 source