Suspicious Activity Reporting in New Zealand
A practical guide to recognising, assessing, documenting and filing suspicious activity reports with the New Zealand FIU.
How this guide was researched and reviewedOn this page
Short answer
Except for law firms and high-value dealers, a reporting entity must report as soon as practicable and no later than three working days after forming reasonable grounds for suspicion. A law firm must report as soon as practicable and no later than five working days, subject to the privileged-communication exception. A high-value dealer may report voluntarily.
There is no minimum value. Suspicious activity can exist without a completed transaction, and an attempted or non-financial activity can matter.
At a glance
The Four-Step Reporting Path
Notice
Staff and monitoring identify unusual activity, information or behaviour.
Review
Relevant facts are checked promptly and without alerting the customer.
Decide
An authorised person decides whether reasonable grounds for suspicion exist.
File
A clear report is submitted through goAML within the deadline that applies to the reporting entity; high-value dealers may report voluntarily.
Plain English
Key Words Explained
These words are used in the law and official guidance. This is what they mean on this page.
- SAR
- Suspicious activity report. It is the broad legal term for reporting suspicious activity, with or without a transaction; high-value dealers may submit one voluntarily.
- STR
- A report type used in goAML when the suspicious activity includes one or more transactions.
- Reasonable grounds
- Facts that provide an objective basis for suspicion. Proof of a crime is not required.
- FIU
- The New Zealand Police Financial Intelligence Unit, which receives and analyses reports.
- goAML
- The secure online system used to submit SARs, STRs and prescribed transaction reports.
Part 1
Recognise and Escalate Concern
- The customer hides ownership, authority, purpose or the people behind the activity.
- Transactions are unusually large, complex, rushed, split or circular.
- The activity does not fit the customer’s known business, income, wealth or purpose.
- Money or property passes through unrelated people, companies, trusts or countries without a clear reason.
- Documents and explanations conflict or change when questioned.
- The customer tries to avoid a reporting threshold or normal CDD.
The SAR test is based on suspicion, not the amount. For an entity subject to the mandatory duty, low-value, attempted or non-transaction activity can still require reporting. A high-value dealer may report voluntarily.
Part 2
Assess and Record the Facts
- Step 1
Gather available information
Review CDD, beneficial ownership, purpose, customer risk, communications, transactions, alerts and earlier activity.
- Step 2
Ask normal and proportionate questions
CDD and service questions may be asked, but the customer should not be told that a report is being considered.
- Step 3
Test the explanation
Compare the answer with documents, expected activity, source information and reliable external information.
- Step 4
Record when the test is met
Record the facts, the decision maker, the time reasonable grounds were formed and the reason for reporting or not reporting.
Part 3
Submit a Clear Report
Except for law firms and high-value dealers, a reporting entity must submit a SAR or STR through goAML as soon as practicable and no later than three working days after reasonable grounds for suspicion are formed.
A law firm must report as soon as practicable and no later than five working days, subject to the privileged-communication exception. A high-value dealer may report voluntarily.
The narrative should make the story easy to follow. Explain who was involved, what happened, when and where it happened, why it is suspicious and what documents or transactions support that view.
| Report | When used | Key point |
|---|---|---|
| SAR | Suspicious activity without a transaction | No minimum value is required. |
| STR | Suspicious activity with one or more transactions | Include the relevant transaction details. |
| LCT or IFT | A prescribed cash or international transfer threshold is met | A separate SAR or STR may also be required for an entity subject to the mandatory duty; a high-value dealer may submit one voluntarily. |
Part 4
Protect the Report and Respond
- Restrict access to the report and the information that reveals it.
- Do not tell the customer or an unauthorised person about the report.
- Apply enhanced CDD or other controls where the relationship continues and the law requires it.
- Consider monitoring, limits, approval, refusal or exit without revealing protected information.
- Keep the decision, supporting evidence, report and goAML receipt.
- Law firms should apply current guidance on privileged communications and suspicious activity reporting.
Part 5
Common Mistakes
- Waiting for proof rather than applying the reasonable-grounds test.
- Treating an alert as a suspicion without reviewing the context.
- Failing to record when the applicable statutory reporting period started.
- Writing a report that lists flags but does not explain the story.
- Discussing the report too widely.
- Assuming a prescribed transaction report replaces a SAR or STR.
Helpful answers
Common Questions
Short answers to the questions businesses ask most often.
Must money move before a SAR is required?
No. Suspicious activity can be reported even when no transaction occurred. The correct goAML report type depends on the facts.
How long is the reporting deadline?
Except for law firms and high-value dealers, the report is due as soon as practicable and no later than three working days after reasonable grounds for suspicion are formed. A law firm must report as soon as practicable and no later than five working days, subject to privilege. A high-value dealer may report voluntarily.
Is a large cash report the same as a suspicious report?
No. LCT and IFT reports are based on prescribed thresholds. A separate SAR or STR may be required for an entity subject to the mandatory duty when the activity is also suspicious; a high-value dealer may submit one voluntarily.
Can the customer be asked more questions?
Normal, proportionate CDD questions can be asked. Care is needed not to disclose the report or prejudice an investigation.
Does privacy law stop a SAR?
No. The Act authorises or requires reports according to the reporting entity’s status. A good-faith report is protected, and a mandatory reporting duty overrides conflicting privacy obligations to the relevant extent.
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 guidanceNew Zealand Police Financial Intelligence UnitSuspicious Activity and Transaction Reports
FIU instructions for suspicious activity and transaction reports. Statutory deadlines and sector exceptions should be checked against the current Act.
- Regulator guidanceDepartment of Internal AffairsPrivileged communications and suspicious activity reporting
Current guidance for law firms on privilege and suspicious activity reporting.
- Regulator guidanceDepartment of Internal AffairsHigh-value dealers guidance 2026
Current guidance on high-value dealer CDD, records, prescribed reports, voluntary SARs and audit requests.
- Regulator guidanceDepartment of Internal AffairsAML/CFT Programme Guidance 2026
Current guidance on establishing, implementing, maintaining and reviewing an AML/CFT programme.