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With civil and criminal penalties at play, AML/CFT obligations come with high stakes. We can help reduce the risk.

The Anti-Money Laundering and Countering Financing of Terrorism (AML/CFT) Act 2009 is designed to protect the New Zealand financial system but can seem complicated and onerous to implement. Widely regarded as experts on AML/CFT, we have the banking and finance, regulatory, and litigation and dispute resolution expertise you need to comply with your AML/CFT obligations. 

We advise banks, financial institutions, and virtual asset service providers (VASPs) on the AML/CFT implications and compliance arrangements for a wide range of financial services.

We regularly assist our clients with:

  • The application of the AML/CFT regime to businesses
  • Applications for exemptions to the AML/CFT regime
  • Implementing and revising AML/CFT internal compliance and reporting structures and programmes
  • Digital identity in the context of AML/CFT
  • Internal investigations of potential non-compliance with AML/CFT requirements
  • Suspicious activity reporting 
  • Prescribed transactions reporting obligations
  • Liaising with regulators, such as the Financial Markets Authority (FMA) and the Reserve Bank of New Zealand (RBNZ), and other government agencies.

We are thought leaders and change makers in the AML/CFT area. Most recently, partner Lloyd Kavanagh was a member of the Ministry of Justice’s Industry Advisory Group which assisted with its Statutory Review of the AML/CFT Act. He is also the author of the Anti-Money Laundering and Countering Financing of Terrorism chapter of Morison’s Company and Securities Law, and well recognised as a leader in the field. 


[MinterEllisonRuddWatts'] technical knowledge and understanding of the regulatory environment is excellent and [their] AML expertise, in particular, has been invaluable.The Legal 500 Asia Pacific 2022


Recent highlights
Digital Identity NZ’s AML/CFT report

Assisting Digital Identity NZ (a New Zealand Tech Alliance member) with the preparation of its influential report: “The reliance and reuse of identity verification for AML/CFT purposes” including provision of all the legal content. This involved extensive engagement with the Ministry of Justice, Reserve Bank, Financial Markets Authority and Department of Internal Affairs, as well as leading banks and digital technology providers.  

Advising a major bank on AML/CFT Compliance

Advising a NZ major bank on a range of compliance issues in relation their AML/CFT obligations including advice on their prescribed transaction reporting obligations and international payments assisting with preparations for an onsite RBNZ review, assisting with resolution of issues with the RBNZ. Also advised on potential implications of offshore litigation involving a related entity for AML/CFT breaches in that jurisdiction.

FMA inquiry into Sharesies Limited

Advising Sharesies Limited, a major broking platform, in relation to the FMA’s notice of intention to issue a formal warning under the AML/CFT Act, including supporting it through its engagement with the FMA, providing extensive advice on technical compliance with the AML/CFT Act, and developing a remediation plan. Representing Sharesies Limited in a hearing with the FMA, and negotiating the terms of the formal warning to accurately reflect the outcome (which was much narrower than the original allegation).

Assisting with AML/CFT compliance for a large Australian private equity firm 

Advising a large Australian private equity firm on the application of the AML/CFT Act to its wholesale investment vehicles, the steps required for compliance (including preparing an AML/CFT Risk Assessment and Compliance Programme compliant with both New Zealand and Australian requirements), and engagement with the FMA.

Assisting with AML/CFT compliance for an Australian finance company

Advising an Australian based finance company on the application of the AML/CFT Act to its NZ operations, the steps required for compliance (including preparing an AML/CFT Risk Assessment and Compliance Programme compliant with both NZ and Australian requirements)

Engaging with regulators on behalf of REINZ to rationalise the application of the AML/CFT regime.

Advising the Real Estate Institute of New Zealand (which represents more than 14,000 real estate professionals in New Zealand) in respect of the application of the AML/CFT Act to real estate agents. Engaging with regulators in respect of proposed amendments to the AML/CFT regime, resulting in revisions to the application of the regime to property management activities to substantially lessen the burden on the industry.