AML/CFT Guide for Money and Remittance Services in New Zealand
New Zealand money and remittance businesses are reporting entities when they provide captured transfer, payment or exchange activities in the ordinary course of business. 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 money and remittance businesses are reporting entities when they provide captured transfer, payment or exchange activities in the ordinary course of business.
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
Remittance moves value quickly, often across borders and through agents or third-party accounts. The entire network and settlement path should be visible.
- Transferring money or value for a customer.
- Changing money or providing relevant payment services.
- Operating through agents or a network to deliver a captured service.
- Using accounts to receive, pool, settle or pay customer transfers.
- Providing another captured financial or virtual-asset activity.
A bank, agent, platform or overseas partner does not automatically carry the New Zealand provider’s duties. Each party’s role, territorial link and information access 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.
- Fast cross-border transfers can move criminal proceeds before detection.
- Agents and third-party accounts can hide the provider and flow of value.
- Structuring, mules and identity fraud can spread activity across small transactions.
- High-risk corridors, cash and informal networks can obscure source and purpose.
- Many senders to one beneficiary can indicate scams or criminal collection.
Part 3
A Practical Control Plan
- Step 1
Confirm scope
Map the service, territorial link, agents, settlement accounts and flow of value.
- Step 2
Build the customer process
Confirm AML Online and goAML registrations and contact details.
- Step 3
Set the risk controls
Set CDD, sanctions, customer-risk and monitoring rules for each channel and corridor.
- Step 4
Train and connect people
Control agents through onboarding, agreements, training, data and testing.
- Step 5
Test and improve
Reconcile SAR, STR, LCT and IFT reporting with transaction records.
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 |
|---|---|---|
| One customer makes repeated transfers below an internal threshold. | The pattern may be structuring or an attempt to avoid attention. | Join the activity across channels, review purpose and beneficiaries and assess a SAR or STR. |
| A remitter uses a family member’s bank account. | The activity may be hidden from the bank and AML/CFT systems. | Stop and assess the arrangement, make the account use transparent and consider compliance and reporting impacts. |
| Several unrelated senders pay one overseas beneficiary. | The beneficiary may be a scammer, mule or criminal collection point. | Aggregate beneficiary activity, review relationships and use corridor intelligence. |
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.
- A network map of agents, partners, accounts, systems and settlement flows.
- Monitoring that joins senders, devices, funders, beneficiaries and corridors.
- Agent training, testing, incidents and remedial actions.
- Reconciliation between transaction data and goAML reports.
- Customer, beneficial ownership, risk, monitoring and reporting records.
- Training, internal review, independent assurance and remediation records.
Part 6
Common Mistakes
- Monitoring transfers one by one.
- Using third-party bank accounts without transparency or risk controls.
- Failing to oversee agents.
- Treating IFT reporting as a substitute for suspicious activity review.
- Missing linked senders, beneficiaries, devices and accounts.
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?
Map the service, territorial link, agents, settlement accounts and flow of value.
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.
Can a remitter use a third-party bank account?
DIA does not endorse hiding remittance activity through another person’s account. Any arrangement must be lawful, transparent and fully addressed in the risk assessment and programme.
Does an IFT report replace a SAR or STR?
No. A prescribed report is threshold based. A separate suspicious report is required when reasonable grounds for suspicion exist.
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 AffairsFinancial institutions and casinos: money remittance
Current DIA guidance and resources for money remitters, money changers and payment businesses.
- 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.