Changes to the Anti Money Laundering and Countering Financing of Terrorism regime

The past week has seen some interesting developments in New Zealand’s anti-money laundering framework under the Anti Money Laundering and Countering Financing of Terrorism regime. We outline brief summaries of these developments below.

 

Statutes Amendment Act 2025 passed under urgency

There is an early Christmas present for compliance teams at ‘reporting entities’ under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML / CFT Act).

At our most recent Investment Funds Industry Update, we spoke about the ongoing AML / CFT Act reforms. These reforms included three bills:

• Statutes Amendment Bill;
• Anti Money Laundering and Counter Financing of Terrorism Amendment Bill; and
• Anti-Money Laundering and Countering Financing of Terrorism (Supervisor, Levy, and Other Matters) Bill.

At the time of the event none of the Bills had progressed, so it seemed unlikely that they would pass this year. However, the Statutes Amendment Bill was passed under urgency and came into force on 27 November 2025.

The Statutes Amendment Act 2025 makes a number of minor technical changes to a wide range of legislation, including the AML / CFT Act. These changes aim to ease the compliance burden for reporting entities by:

• removing the requirement to verify address information where standard customer due diligence is being conducted; and
• extending the timeframe for filing prescribed transaction reports from 10 to 20 working days.

The other Bills both continue to be at the Second Reading stage.

 

Proposed changes to AML / CFT Identity Verification Code of Practice (IVCOP)

On 24 November, the three joint AML regulators (the Financial Markets Authority, the Department of Internal Affairs, and the Reserve Bank of New Zealand) opened consultation on proposed changes to the AML / CFT IVCOP.

The consultation proposes a number of changes to the IVCOP. Importantly, these include:

• allowing trusted referee certification only where verification cannot be completed face-to-face and requiring the reasons to be documented;
• suggesting certified copies of identity documents must be in "wet ink" form or signed using an electronic signing platform, casting doubt on the ability to use scanned copies; and
• providing a list of reliable electronic sources of identification and removing the requirement to obtain a second corroborating electronic source.

Consultation on these proposals closes on Monday, 19 January 2026.

 

Our view

The Statutes Amendment Act changes are helpful. They address a longstanding anomaly in the New Zealand AML / CFT regime which has been unusual internationally in requiring address verification. The extra time to file prescribed transaction reports will also be welcomed by compliance officers and reporting entities.

We expect the IVCOP proposals will receive a mixed reception. Some of the proposals are overdue improvements that will help facilitate electronic on-boarding processes. However, others – particularly those imposing additional restrictions and requirements on the trusted referee pathway – are likely to encounter resistance, as they may raise questions about reliance on existing processes and may result in additional compliance costs for some reporting entities.

Please reach out if you would like to discuss these changes further.