The Ministerial Advisory Group on Transnational, Serious and Organised Crime released its final report, Leading Boldly, Acting Decisively. The report identifies organised crime as New Zealand’s most serious national security threat and calls for bold, system-wide reform. Proposed changes include a new national enforcement structure, sweeping regulatory reforms, and enhanced powers to disrupt criminal networks. These proposals carry significant implications for regulated entities, professional advisers, and businesses across multiple sectors.

This alert summarises the report’s key findings and recommendations, outlines expected next steps, and explains how MinterEllisonRuddWatts’ Corporate Crime and Investigations team can help clients navigate the evolving landscape.

Who needs to read this and why

Regulated entities, legal practitioners, compliance professionals, and businesses operating in high-risk sectors - including finance, construction, hospitality, and professional services - should closely review the proposed reforms.

Major reform proposed to combat organised crime

Background and context

The Ministerial Advisory Group (Group) on Transnational, Serious and Organised Crime (TSOC) was established by Hon Casey Costello to advise the New Zealand Government on how to respond to the escalating threat of organised crime. After six months of intensive stakeholder engagement and analysis, the Group released its final report proposing a bold, system-wide reform agenda. Key structural recommendations include the appointment of a dedicated Minister, a refreshed TSOC Strategy, an executive board, and the creation of a TSOC Business Unit - each focused on prevention, accountability, and coordinated action across government, communities, and international partners.

Key findings: Organised crime as a national security threat

The report identifies organised crime as New Zealand’s most serious national security threat - driving violence, corruption, and financial harm. Criminal networks are fuelling methamphetamine addiction, cyber fraud, migrant exploitation, black market tobacco distribution, and gang violence, while undermining institutions and damaging New Zealand’s international reputation.

Despite the efforts of frontline agencies, the Group concludes that New Zealand’s response is fragmented and falling short. The message is clear: New Zealand is at a tipping point, and bold, coordinated action is urgently required.

Proposed reforms: Legal and compliance implications

The report recommends the following substantial reforms to New Zealand’s AML/CFT regime and broader regulatory settings. If implemented, these changes will significantly affect regulated entities, legal practitioners, and compliance professionals across multiple sectors:

• Expanded definition of money laundering: A proposed strict liability offence would make individuals and entities criminally liable for dealing with property known or suspected to be the proceeds of crime - unless they can prove a reasonable belief that it was not. This reverses the burden of proof and lowers the liability threshold, with significant implications for regulated entities, advisers, and financial service providers.

• Strengthened asset recovery powers: Authorities would gain powers to automatically confiscate cash found with illicit items, seize undeclared cash over NZD1,000 at the border, and confiscate property used to facilitate crime - even without a conviction. These tools aim to disrupt organised crime where prosecutions are slow or impractical.

• Mandatory electronic wage payments in high-risk sectors: Employers in construction, hospitality, and agriculture would be required to pay wages electronically, effectively banning cash payments. This targets tax evasion and migrant exploitation, but may affect financial inclusion for over 50,000 New Zealanders without access to banking.

• Ban on cash payments for professional services: A proposed prohibition on all virtual currency ATMs until regulatory oversight as part of the overhaul of the AML/CFT regime.

• Enhanced due diligence for digital finance and remittance providers: These entities would be classified as high-risk under AML/CFT rules, triggering stricter compliance obligations and increased regulatory scrutiny.

• Expanded investigative powers: Police could restrain property belonging to deportees suspected of importing illicit wealth, even without a local investigation. Convicted offenders may face financial audits for up to seven years post-conviction - raising privacy and due process concerns.

• Improved data sharing and surveillance tools: Agencies would be empowered to share data and use real-time monitoring tools, including transaction freezes and bank account surveillance. These measures raise privacy implications, particularly around access to financial and telecommunications data.

• Corruption law reform and national strategy: Proposed changes include updating definitions of “corruption” and “bribery,” increasing penalties, and treating such offences as aggravating factors in sentencing. A national anti-corruption strategy is recommended, led by a central authority to manage system-wide risks.

Next steps

Public consultation is expected to open shortly, with final decisions anticipated in early 2026. Legislative changes may follow quickly. Businesses in sectors identified as high-risk - including finance, construction, hospitality, and professional services - should begin reviewing their compliance frameworks and considering the potential impact on them.

While we acknowledge the concerns the Ministerial Advisory Group has about the increasing level of organised crime, many of the proposals raise serious issues in terms of fairness and the rule of law which need to be considered too. Businesses and professionals should act now to understand the potential impact, consider whether to make submissions to Government when consultation opens and prepare for the potential of change.

How we can help?

These proposals signal the potential for a significant shift in New Zealand’s approach to financial crime, and may have profound consequences to many legitimate businesses and everyday New Zealanders.

Our Corporate Crime and Investigations team at MinterEllisonRuddWatts is well-placed to assist clients in understanding and responding to the proposals. We can also assist with reviews of compliance frameworks should the proposals proceed.

We offer support in:

• advising on anti-bribery and corruption policies and cross-border financial crime risks;

• reviewing AML/CFT compliance frameworks and risk assessments;

• advising on employment law implications of electronic wage mandates;

• preparing submissions to Government during the consultation period;

• supporting professionals working with vulnerable or “debanked” clients; and

• navigating banking relationships and enhanced due diligence obligation.

We combine deep regulatory expertise with practical industry insight to help clients stay ahead of change.

This article was co-authored by Sian Vaughan-Jones, Solicitor, in our Corporate and Commercial team.