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Does AML/CFT Apply to My Business in New Zealand?

Find out, in plain English, whether New Zealand’s AML/CFT rules may cover an activity your business carries on.

Prepared bySeamless AML

How this guide was researched and reviewed

On this page

2-minute checker
Short answer
Three simple checks
Key words explained
Who this applies to
The detailed test
Practical examples
Common mistakes
What to do now
Common questions
Official sources

Interactive screening toolAbout 2 minutes

New Zealand • AML/CFT

Check Whether AML Rules May Apply to Your Business.

Answer four short questions about one service or activity. You will get a simple result and links to the official information.

No contact details are required.
Your answers stay in this browser and are not saved.
You can repeat the check for another service line.

This tool gives general information, not legal advice. It cannot cover every service, rule, exemption or situation.

Short answer

The rules may apply if all three points below are true. The business does work named in the law. The work is a normal part of the business. The work also has a strong link to New Zealand.

Your job title does not decide the answer. What you do does. The law calls a person or business covered by the Act a reporting entity.

At a glance

The Three Things to Check

1
Is the activity named in the law?
The law lists some work done by banks, lenders, lawyers, accountants, real estate agents, casinos and high-value dealers.
2
Is it a normal part of the business?
The law calls this the ordinary course of business. Look at the work the business does in real life.
3
Is it linked to New Zealand?
Look at where the work happens. Then check its links to people, customers, property, money and business systems in New Zealand.

Plain English

Key Words Explained

You will see these words in the law and official guidance. Here is what they mean on this page.

AML/CFT: Rules that help stop money laundering and terrorism financing.
Reporting entity: A person or business that must follow the AML/CFT Act for a covered activity.
Ordinary course of business: Work that forms part of how the business normally operates. Several facts can affect this test.
New Zealand connection: The links between the activity and New Zealand. A physical office is not always needed.
DIA: The Department of Internal Affairs, which supervises New Zealand reporting entities.

Who This Applies To

Use this guide if you are starting a business, adding an activity or checking an overseas business’s link to New Zealand.

People and businesses that carry on a listed financial activity.
Lawyers, conveyancers, accountants, real estate agents and trust or company service providers that carry out listed work.
Casinos, online casino operators, some high-value dealers and TAB NZ.
New Zealand businesses serving overseas customers.
Overseas businesses that direct listed activities to New Zealand.

This is a screening guide. Close cases can turn on the exact service, customer, transaction, business structure and any applicable exemption.

The Detailed Test

Work through these steps in order. Write down the facts and the law or official guidance used for each answer.

01
Check the activity
Start with what the business actually does. Then compare it with section 5 of the Act. The law covers listed financial activities and some work done by lawyers, accountants, real estate agents and trust or company service providers. It also has separate rules for casinos, online casinos, high-value dealers and TAB NZ.
Write down
- Which legal category may apply?
- What does the business actually do for the customer?
- Does the law set a customer, value or transaction condition?
02
Check how the activity fits the business
The law calls this the ordinary course of business. Ask whether the activity is part of how the business normally works. DIA looks at how often it happens, its size, the resources used and whether it is offered to customers. No single fact decides the answer.
Write down
- Does it appear in normal systems, training or customer information?
- How often does it happen?
- What staff, time, money or systems does the business use for it?
03
Check the link to New Zealand
Look at where the activity happens and how it is linked to New Zealand. Staff, agents, customers, marketing, payments, instructions, property, companies and trusts can all matter. A physical office is not always needed. A website that can be viewed in New Zealand is not enough on its own.
Write down
- Where are the people, decisions and main parts of the work?
- Is the activity aimed at New Zealand or often provided here?
- Does it use New Zealand money, property, companies, trusts or business systems?

If the answer is yes

If all three checks are met, the person or business is likely to be a reporting entity for that activity. Check current regulations, DIA rules, notices and exemptions before you rely on the answer.

Practical Examples

These examples help identify the boundary. They do not replace the wording of the legislation.

Law, accounting and trust services

May be relevant when: Some work involving companies, trusts, nominees, business addresses, client money, property or business transactions may be covered.
Check the boundary: The job title does not cover every piece of work. Check whether the business normally carries out a listed activity.

Real estate

May be relevant when: Real estate agency work done to make a property transaction happen may be covered.
Check the boundary: Other work is not covered just because a licensed real estate business performs it.

Financial activities

May be relevant when: Deposits, loans, money transfers, payments, guarantees, trading, custody, funds, life insurance and currency exchange are among the listed activities.
Check the boundary: The activity must still be a normal part of the business and have the required New Zealand link.

Overseas and online businesses

May be relevant when: Regular New Zealand customers, local marketing, onboarding, payments or support may create a strong enough link.
Check the boundary: A website that can be viewed here, a few unexpected users or one accidental transaction is not enough on its own.

High-value dealers and gambling

May be relevant when: Some high-value art or cultural-goods dealers, casinos, online casinos and TAB NZ have their own reporting-entity categories.
Check the boundary: Check the exact goods, cash amount and current rules. Separate rules ban cash payments of NZ$10,000 or more for some other high-value goods.

Common Mistakes

01
Assuming every service from a listed profession is covered.
02
Skipping the ordinary-course test or using only one fact to decide it.
03
Looking only at where the business is registered or has an office.
04
Assuming an overseas customer puts a New Zealand business outside the rules.
05
Using old material that still refers to three supervisors. DIA has been the sole AML/CFT supervisor since 1 July 2026.
06
Forgetting to check current regulations, DIA notices and exemptions.

What to Do Now

01
Write down every activity the business carries on or plans to carry on.
02
Match each activity to the right category in section 5 of the Act.
03
Record how the activity fits the normal work of the business.
04
Record where the activity happens and its links to New Zealand.
05
Check current regulations, DIA rules, notices, guidance and exemptions.
06
If the rules apply, contact DIA and set up the required AML/CFT systems and controls.

Use the print button at the top of this page to keep this action list with your scope record.

Common Questions

Short answers to the questions businesses ask most often.

What is a reporting entity?

It is a person or business that must follow the AML/CFT Act for a covered activity. Not every financial service provider or listed professional is a reporting entity for every activity.

Does AML/CFT apply to every accountant, lawyer or real estate agent?

No. The business must carry out a listed activity in the ordinary course of business and have the required New Zealand link.

What does ordinary course of business mean?

It means the activity forms part of how the business normally works. DIA looks at several facts, such as frequency, size, staff, systems, marketing and professional context.

What if the customer is overseas?

An overseas customer does not put a New Zealand business outside the Act. You still need to check where the work happens and its links to New Zealand.

Is every financial adviser a reporting entity?

No. Giving financial advice on its own does not automatically make a person a reporting entity. Other activities, such as handling client money or arranging certain services, may change the answer.

Can an exemption or DIA notice change the answer?

Yes. Regulations, DIA notices and exemptions can change who or what is covered. Check the current official material before relying on a result.

Official Sources

The guide cites the following sources.

Primary lawNew Zealand Legislation
Anti-Money Laundering and Countering Financing of Terrorism Act 2009
Sections 5 and 6. Version current from 1 July 2026.
Regulator guidanceDepartment of Internal Affairs
Territorial Scope of the AML/CFT Act 2009
Three-step territorial-scope test. Version 2.0, 1 July 2026.
Regulator guidanceDepartment of Internal Affairs
Interpreting Ordinary Course of Business
Factors for deciding whether a captured activity is part of ordinary business.
Regulator guidanceDepartment of Internal Affairs
AML/CFT information for businesses
Current guidance, onboarding information and supporting material.