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nid 94614
Aug 18, 2026
kgurnani@vixio.com
New Zealand
Department of Internal Affairs
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2032 charsNew Zealand Department of Internal Affairs Publishes Comprehensive AML/CFT Guidance Update Summary
On August 17, 2026, the Department of Internal Affairs published a comprehensive suite of updated anti-money laundering and counter-terrorism financing (AML/CFT) guidance to support reporting entities following the transition to a sole AML/CFT regulator. To assist reporting entities in understanding the changes, the department released a new Guidance Update Summary, which provides an overview of key changes across each guidance document in a single reference document.
The Guidance Update Summary is intended as a quick reference tool to help reporting entities identify what has changed and determine where they may need to review their existing AML/CFT policies, procedures, and controls. The summary should be read alongside individual guidance documents. Key guidance documents covered in the update include Risk Assessment Guidance, AML/CFT Programme Guidance, Enhanced Customer Due Diligence Guidance, A Guide to Complying with the AML/CFT Act, AML/CFT Reporting Entity Quick Start Guide, Customer Due Diligence Guidance, and a Practice Note for Non-Bank Financial Institutions addressing wire transfers and prescribed transaction reporting. The summary explains where new guidance has been introduced and highlights significant changes to existing guidance. The updated guidance package reflects the regulatory changes following the establishment of a sole AML/CFT regulator, streamlining compliance requirements across the sector. This development is significant for all reporting entities operating in New Zealand, as it provides clarity on evolving regulatory expectations and assists in maintaining compliance with AML/CFT obligations.
Reporting entities should review the Guidance Update Summary and relevant individual guidance documents to ensure their compliance frameworks remain current. For further information or queries regarding the updated guidance, reporting entities can contact the AML/CFT team at amlcft@dia.govt.nz. The guidance documents are available on the Department of Internal Affairs website.
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2961 charsNew Zealand Department of Internal Affairs Publishes Comprehensive AML/CFT Guidance Update Summary
On August 17, 2026, the Department of Internal Affairs published a comprehensive suite of updated anti-money laundering and counter-terrorism financing (AML/CFT) guidance to support reporting entities following the transition to the Department of Internal Affairs (DIA) as the sole AML/CFT regulator.
The guidance package is essentially a collation of several individual guidance documents. Key changes and information in these guidance documents are:
Risk assessments and AML/CFT programmes : Reporting entities must incorporate relevant money laundering, terrorism financing and proliferation financing risks identified by DIA or the New Zealand Police Financial Intelligence Unit (FIU). Risk assessment guidance has also been reorganised and expanded with material on reviewing risk assessments, self-laundering, professional laundering networks and practical risk examples.
Customer due diligence and politically exposed persons (PEPs) : Updated CDD guidance introduces a more explicitly risk-based approach to politically exposed person checks, requiring entities to take reasonable steps according to the level of risk. The 2026 Identity Verification Code of Practice has also been incorporated, including changes to the treatment of high-risk customers and beneficial owners.
Trusts : Enhanced CDD and trust guidance has been revised around verification of source of funds/source of wealth and the address or registered office of trust customers, with additional DIA guidance on applying these requirements proportionately according to risk.
CDD guidance across different entity types : DIA has refreshed guidance for companies, trusts, limited partnerships, clubs and societies, co-operatives, and sole traders/partnerships. Common changes include risk-based PEP checks, customer risk-rating requirements, address verification changes, beneficial ownership requirements and more information on suspicious activity reporting through the FIU's goAML system.
Determining whether the AML/CFT Act applies : Guidance on “ordinary course of business” now gives clearer factors and a flowchart for determining reporting-entity status. Territorial-scope guidance now provides a decision-making framework, scenarios and factors for establishing whether an overseas or cross-border business has a sufficient New Zealand connection to fall under the Act.
Country risk : Guidance has been expanded on UN sanctions and embargoes, correspondent banking and shell banks, and now expressly requires entities to incorporate relevant risks identified by DIA or the FIU into their assessments.
Outsourcing : The previous CDD outsourcing guidance has been substantially expanded into broader guidance on outsourcing to third-party agents. It now covers AML/CFT risks arising from outsourcing, outsourced transaction monitoring, Privacy Act considerations and third-party software solutions, while clarifying that the reporting entity retains its AML/CFT obligations.