December issue

Kia ora

As we wrap up 2025, this final edition of In the Know reflects on a year of collaboration and progress across the AML/CFT system. 

We report on:

• recent legislative changes intended to provide regulatory relief, including the removal of address verification requirements in most cases
• an update from the Financial Action Task Force to its “grey list”
• new and updated guidance; and
• the successful ACAMS/FIU conference in Wellington.

We are also preparing for the transition to a single AML/CFT supervisor model on 1 July 2026, working closely with the Reserve Bank of New Zealand and the Financial Markets Authority to ensure a smooth changeover. 

Finally, consultation is now open on the proposed Identity Verification Code of Practice. Your input is important to ensure it is fit for purpose and works well in practice. I encourage you to review the proposal and provide your feedback.

Thank you for connecting with us this year. Wishing you a safe, restful holiday season and we look forward to sharing more updates in the new year. 

Ngā mihi nui,
Serge Sablyak
Director AML/CFT

Move to single AML/CFT Supervisor

DIA continues to build on our strong engagement focus as we move to the new single supervisor model next year on July 1. 

Working closely with the Reserve Bank of New Zealand and the Financial Markets Authority; and as part of our engagement planning, we have now established 3 industry reference groups: 

• Industry Reference Group (IRG)
• Banking and Non-Deposit Taking Reference Group (BNBRG)
• Financial Markets Reference Group (FMRG) 

By engaging in open and transparent conversations early and often we’re continually learning and building trust and understanding to ensure a smooth transition. 

We continue working on our engagement planning and we’ll be back in the New Year with plenty more to share.  

FATF Plenary Update

The Financial Action Task Force (FATF) has updated its list of jurisdictions under increased monitoring — commonly referred to as the “grey list” — following its October 2025 plenary. 

While no new jurisdictions were added, some have made progress toward addressing their strategic AML/CFT deficiencies. Reporting entities should stay informed about these developments to keep risk assessments current and aligned.

Read the full update on our website:

Legislative changes

The Statutes Amendment Act 2025 has introduced changes to the AML/CFT Act that provide regulatory relief and simplify compliance for reporting entities and their customers.

Verifying the address of a customer, a beneficial owner, or a person acting on behalf of a customer is no longer required as part of standard customer due diligence. Verification is still required as part of enhanced customer due diligence.

Other updates include:

• extending the time for businesses to file prescribed transaction reports from 10 to 20 working days
• extending the maximum time for a law firm to submit a suspicious activity report from 3 to 5 working days; and
• amending the definition of ‘occasional transaction’ to clarify that cheque deposits made at a registered bank or a non-bank deposit taker are excluded from the definition.

These changes have taken effect, and entities should update their requirements and processes accordingly.

More regulatory relief is on the way as part of the Government’s legislative reform programme. We expect further amendments to be enacted in 2026.

ACAMS/FIU Conference

Last month, we joined more than 500 participants at the 2025 ACAMS/FIU Conference in Wellington, New Zealand’s largest AML/CFT event. The conference brought together law enforcement, regulated entities and regulators, to share insights and to strengthen collaboration.

Over two days, we heard from local and international experts, connected with AML/CFT professionals across the private and public sectors, and shared our vision for fighting crime by strengthening compliance.

On 3 November, we hosted a full pre-conference workshop for DIA sector attendees. This session allowed us to share information, foster new relationships and enhance collaboration with our regulated sectors – something we’re looking to do more of in 2026 and beyond.

New and Updated Guidance

New and updated AML/CFT guidance is now available on our website to help reporting entities meet their obligations under the AML/CFT Act. Explore the latest resources by clicking on the images below. These materials are designed to help you understand your responsibilities and apply best practice in your compliance processes.

Enforceable undertakings

The Department has entered into enforceable undertakings with two reporting entities following identified non-compliance with AML/CFT obligations. Both reporting entities have agreed they will not carry out any activities that are subject to the AML/CFT obligations.

Read more about the undertakings below.

$5.06 million penalty confirmed for AML/CFT breaches 

The High Court has confirmed a civil pecuniary penalty against Christchurch Casinos Limited of $5.06 million for breaches of the AML/CFT Act
 

Have your say on the Identity Verification Code of Practice

The Identity Verification Code of Practice (IVCOP) is being reviewed for the first time since 2013. The AML/CFT Supervisors are seeking public feedback on proposed changes to reflect modern identification practices, support digital identity solutions and reduce compliance burden while maintaining system integrity under the AML/CFT Act.

Nine proposals are on the table, including new verification pathways and clearer rules for high-risk customers. Your input will help shape how identity verification works in New Zealand. Consultation is open until 19 January 2026.