The Government has committed to a major overhaul of New Zealand’s AML/CFT regime. The goal? To make AML more agile, truly risk-based, and better aligned with the needs of both industry and the community.

At the centre of these reforms are three key shifts:

• A series of legislative changes, starting with the AML/CFT Amendment Bill, to modernise the regime, strengthen risk-based obligations, and clarify requirements such as customer risk-rating and the treatment of online marketplaces.
• The establishment of a single AML/CFT supervisor (replacing the current three-supervisor model: DIA, FMA, and RBNZ) and the introduction of an industry-wide AML levy to fund the regime in a risk-appropriate and equitable way.
• A forthcoming Omnibus Amendment Bill, which will represent the final phase of reform and is expected to deliver additional technical and operational changes based on the 2022 statutory review.

Here’s what’s happening, and what it means for you.

 

What’s in Progress?

1. AML/CFT Amendment Bill

What it’s about:
Implements legislative changes based on the 2022 statutory review, with a focus on supporting a more risk-based approach to compliance.

Includes:

• Stronger risk-based obligations
• Mandated requirement for reporting entities to risk-rate all new customers (already in effect as of 1 June 2025), including updates to review and to be considered as part of ongoing CDD
• Updated coverage of new business models such as online marketplaces, now subject to the AML/CFT Act
• Updated definitions including “beneficial owner” and “designated non-financial business or profession”
• PTR submission deadlines and risk assessment expectations with guidance material

Status: First Reading complete; before Select Committee
Expected to pass: End of 2025
Key deadline already in force: Risk-rating of new customers from 1 June 2025

 

2. Supervisor, Levy & Related Matters Bill

What it’s about:
Establishes a single AML/CFT supervisor (Department of Internal Affairs) and introduces a new AML Industry Levy to fund the regime.

Includes:

• Supervision of all reporting entities will be consolidated under DIA
• Levy will be designed to target higher-risk sectors and reduce compliance burden on smaller firms
• Intention is to streamline supervision and reduce duplicated efforts across DIA, FMA and RBNZ
• Supports rule-making powers and structural changes to enable a more coordinated and risk‑based system

Status: Drafting underway
Expected to pass: Mid 2026
Levy collection begins: Mid 2027

 

3. AML/CFT Omnibus Amendment Bill

What it’s about:
The final phase of the AML/CFT reform programme. Though specific content has not been released, it is expected to implement remaining recommendations from the 2022 review and reflect international standards set by the FATF.

Expected to include:

• Technical refinements to SAR and PTR processes
• Adjustments to enhance flexibility for Designated Business Groups (DBGs)
• Further streamlining of reporting deadlines and operational processes
• Legal updates that enable a more dynamic and risk-based approach

Status: Drafting in progress
Expected to be introduced: Mid 2026
Likely to pass: Post-election (late 2026 or beyond

 

4. Statutes Amendment Bill

What it’s about:
Introduces minor but impactful changes that support and enable implementation of broader AML/CFT reforms.

Includes:

• Limiting address verification requirements to cases where a specific level of risk has been identified
• Extending the submission window for PTRs from 10 to 20 working days
• Extending the submission window for law firms to submit SARs from 3 to 5 working days

Status: Awaiting Second Reading; Select Committee report published
Expected to pass: By end of 2025

 

Who needs to be aware of these changes?

These reforms apply to all reporting entities under the AML/CFT Act. Boards, CFOs, and senior leaders should be aware of the upcoming AML levy and its budget implications. Compliance Officers must implement changes to customer due diligence, including the now-mandated requirement to risk-rate all customers, as well as updated reporting obligations. Entities currently supervised by the FMA or RBNZ should be aware of the upcoming transition to the Department of Internal Affairs as the single AML/CFT supervisor.

 

What should you be doing now?

• Monitor the progress of the above Bills through Parliament
• Monitor consultation periods – your sector feedback can shape final bill design
• Review your AML/CFT programme, especially CDD, SAR/PTR timelines, and risk‑rating processes – this helps ensure your current processes meet the latest requirements. With risk-rating changes now mandatory and reporting timeframes changing, it’s important to keep your Compliance Programme up to date.

 

Dates to watch

Key Change	Expected Date
Individual risk-rating requirement	In force since 1 June 2025
Statutes Amendment Bill passed	End of 2025
AML/CFT Amendment Bill passed	End of 2025
Supervisor & Levy bill passed	Mid-2026
Omnibus Bill passed	Late 2026
AML Levy implemented	Mid-2027

You can follow the progress of these bills on NZ Parliament, which lists updates, readings and Select Committee reports as they happen.

 

Final Thoughts

New Zealand’s AML/CFT framework is entering a period of significant change, shifting how compliance is overseen, funded and implemented. With key bills progressing through Parliament and new obligations already taking effect, now is the time for reporting entities to get prepared.

Our consultants are available to talk through what these changes mean for you, and how to get ahead of them.

Speak to our team for more information.