The Statutes Amendment Act (the Act) received the Royal Assent on 26 November 2025 and will come into force on 27 November 2025. The Act amends 42 Acts, including technical changes to the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT Act) and the Credit Contracts and Consumer Finance Act 2003 (CCCFA), which are discussed in this Alert.
The Act can be found here and the Beehive release, discussing the Act as it relates to the AML/CFT Act, is available here.
Who needs to read it? Why?
The AML/CFT changes are relevant to all reporting entities under the Act, including:
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Law firms and conveyancers
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Banks and other financial institutions
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Accountants and auditors
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Trust and company service providers
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Casinos and high-value dealers
All reporting entities should prepare for the implementation of the Act as it will require changes to their systems and operations.
Further, lenders should be aware of how its record keeping and disclosure processes may be impacted.
What does it cover?
AML/CFT Act changes
The amendments to the AML/CFT Act contained in the Act give effect to the recommendations contained in the final report of the Ministry of Justice’s Statutory Review of the AML/CFT Act, Report on the review of the Anti-Money Laundering and Countering Financing of Terrorism Act 2009.
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Exclusion of cheque deposits from ‘occasional transaction’ definition clarified: The ‘occasional transaction’ definition has been amended by inserting after the “cheque deposits” the words “made at a registered bank or non-bank deposit taker.”
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Address verification no longer required in all cases when conducting enhanced CDD: The address of a customer, beneficial owner, or person acting on behalf of a customer only needs to be verified according to the level of risk involved.
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Suspicious activity and prescribed transaction reporting timeframes extended:
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Law firms now have a maximum 5 working days instead of 3 to provide suspicious activity reports to the Financial Intelligence Unit;
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and reporting entities now have 20 working days instead of 10 to report on certain prescribed transactions.
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CCCFA changes
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Lenders no longer need to keep records of enquiries relating to declined or withdrawn applications.
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Where two or more persons share the same postal address, disclosure to one is treated as disclosure to all.
Our view
AML/CFT Act
These changes aim to:
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Reduce unnecessary compliance costs for low-risk activities.
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Align New Zealand with the European Financial Action Task Force standards.
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Ease standard CDD requirements.
As we have previously discussed, we welcome these changes as they go towards making compliance more risk-based and efficient, rather than a one-size-fits-all approach. This is in line with the government’s focus on a more common-sense approach to compliance.
We expect these changes to be positively received by many. These changes will ease compliance burdens, particularly for small businesses and low-risk clients. Reporting entities should review and update their AML policies, train staff and adjust onboarding procedures to reflect the new risk-based approach. Compliance teams should ensure policies reflect the approach.
CCCFA
We think these changes represent a positive step toward streamlining compliance for lenders, making the process more efficient and straightforward.
What next?
The Act is set to come into force on 27 November 2025.
If you have any questions in relation to the Statutes Amendment Act or are considering how these changes may affect your business, please contact one of our experts.
This article was co-authored by Leanne Chew, a Solicitor and Vincent Thomas, a Summer Clerk in our Financial Services team.
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