AML/CFT Guide for Accountants, Bookkeepers and Tax Agents in New Zealand
New Zealand accounting businesses are reporting entities when they carry out one or more captured activities in the ordinary course of business. The job title alone does not decide the answer. This guide explains scope, sector risks, practical controls, examples and official sources in plain English.
How this guide was researched and reviewedOn this page
Short answer
New Zealand accounting businesses are reporting entities when they carry out one or more captured activities in the ordinary course of business. The job title alone does not decide the answer.
Scope is based on the listed activity, the ordinary-course test and the New Zealand connection. Check current regulations, exemptions and DIA guidance before relying on a result.
At a glance
Start With These Four Checks
Map the activity
Write down exactly what the business does and match it to section 5.
Know the customer
Identify the customer, beneficial owners, people acting for them and the purpose of the work.
Follow the sector risk
Build controls around how money, property, structures, products and instructions move in this sector.
Keep the evidence
Scope, CDD, risk, monitoring, reports, training and review should be easy to prove.
Plain English
Key Words Explained
These words are used in the law and official guidance. This is what they mean on this page.
- Captured activity
- An activity that brings a person or business within section 5 of the New Zealand AML/CFT Act.
- Reporting entity
- A person or business that must meet AML obligations for the covered service or activity.
- Beneficial owner
- The individual who ultimately owns or controls the customer or on whose behalf the work is done.
- Enhanced CDD
- Extra customer and source checks used when the law or higher risk requires them.
- SAR
- A suspicious activity report submitted to the New Zealand FIU through goAML when reasonable grounds for suspicion exist.
Part 1
When AML/CFT May Apply
Covered work commonly involves transactions, client funds, companies, trusts, nominees or business addresses.
- Managing client funds, accounts, securities or other assets in a captured way.
- Engaging in or giving instructions for real-estate transactions on a client’s behalf.
- Engaging in or giving instructions for transactions involving businesses or legal arrangements.
- Creating companies, trusts or other legal persons or arrangements.
- Providing nominee, trustee, partner, registered-office or business-address services.
- Carrying out other captured trust and company services in the ordinary course of business.
Routine bookkeeping, payroll, tax returns, financial statements and audit work are not automatically captured. A practice may provide both captured and ordinary accounting work, so each service should be mapped.
Part 2
Main Risks in This Sector
These are starting points, not a ready-made risk rating. The business still needs to assess its own customers, services, countries, channels, transactions and technology.
- Companies, trusts and nominees can hide beneficial ownership and control.
- Client funds and transaction work can move criminal proceeds through a trusted adviser.
- Registered addresses and shelf structures can create false legitimacy.
- Cross-border clients and third-party funding can obscure source and purpose.
- Long-standing client familiarity can replace proper CDD when the work changes.
Part 3
A Practical Control Plan
- Step 1
Confirm scope
List the practice’s activities and check section 5 and the ordinary-course guidance.
- Step 2
Build the customer process
Separate captured work from routine bookkeeping, payroll, tax and assurance services.
- Step 3
Set the risk controls
Build CDD and approval gates into transaction, client-fund and structure work.
- Step 4
Train and connect people
Train staff on trusts, nominees, hidden ownership, source and suspicious activity.
- Step 5
Test and improve
Review sample engagements and keep scope, CDD, risk and decision evidence together.
Part 4
Worked Examples
These examples show how the scope and risk questions can be joined. They do not replace the law or the facts of a real matter.
| Situation | Why it matters | Practical response |
|---|---|---|
| An accountant establishes a company and arranges nominee directors. | The service can create a structure that hides the real controller. | Confirm scope, identify beneficial owners and purpose and apply risk-based enhanced checks. |
| A bookkeeper processes ordinary payroll from the client’s account. | The business may apply the Act based only on its job title or misunderstand control of funds. | Analyse the exact activity and record whether it is carried out in the ordinary course and within a captured category. |
| A trust receives a large overseas loan from an unrelated party. | The source, relationship and purpose may be hidden or inconsistent. | Complete enhanced CDD, examine source information and assess suspicious activity reporting. |
Part 5
Evidence That Should Be Easy to Find
- The section 5, ordinary-course and New Zealand connection analysis.
- The current sector risk assessment and the official sources used.
- An activity map distinguishing captured and routine accounting work.
- CDD and source records for trusts, companies and client-fund matters.
- Registers for formations, nominees, trustees and address services.
- Training and file reviews based on the practice’s actual work.
- Customer, beneficial ownership, risk, monitoring and reporting records.
- Training, internal review, independent assurance and remediation records.
Part 6
Common Mistakes
- Treating every accountant or bookkeeper as automatically captured.
- Missing a captured service bundled inside ordinary tax work.
- Identifying the company but not its beneficial owners.
- Treating an old client relationship as a reason to skip updated CDD.
- Failing to examine and record unusual transaction findings.
Helpful answers
Common Questions
Short answers to the questions businesses ask most often.
Does every business in this sector have AML/CFT duties?
No. The exact activity, ordinary-course facts and New Zealand connection decide the answer. A business may carry out both captured and uncaptured work.
What should the business do first?
List the practice’s activities and check section 5 and the ordinary-course guidance.
Can the sector risk assessment replace our own?
No. Official national and sector assessments are important sources, but the reporting entity must assess the risks it reasonably expects to face in its own business.
Can a generic AML/CFT template be used?
A template can help with structure, but it must be matched to the business’s scope, risks, people, systems and evidence. A document that is not implemented is not enough.
Are tax returns captured activities?
Not by themselves merely because an accountant prepares them. Check whether the engagement also includes a listed transaction, company, trust, nominee, address or client-fund activity.
Are bookkeepers always reporting entities?
No. The exact activity and whether it is carried out in the ordinary course of business decide the answer.
Reference
Official Sources
This guide cites the following sources.
- Primary lawNew Zealand LegislationAnti-Money Laundering and Countering Financing of Terrorism Act 2009
The current New Zealand AML/CFT Act, including CDD, programme, reporting, audit and record duties.
- Regulator guidanceDepartment of Internal AffairsInformation for accountants
Current DIA guidance and resources for accounting practices, bookkeepers and tax agents.
- Regulator guidanceDepartment of Internal AffairsAML/CFT Programme Guidance 2026
Current guidance on establishing, implementing, maintaining and reviewing an AML/CFT programme.
- Regulator guidanceNew Zealand Police Financial Intelligence UnitNational Risk Assessment
The March 2025 national assessment of New Zealand money laundering and terrorism financing risk.