The AML/CFT settings have been under review for some time, and many organisations across New Zealand have been calling for more workable, real-world requirements. Last week, the Statutes Amendment Bill passed its final reading, bringing several practical updates into force immediately.

For associations and membership bodies that interact with AML-regulated environments — whether through financial services, professional services, or sector partnerships — these changes will matter.

Address Verification No Longer Required for Standard CDD

The headline change is simple but significant:

Address verification is no longer required as part of standard customer due diligence (CDD).

This step now only applies when there’s a higher-risk situation under enhanced due diligence.

For years, organisations have highlighted the difficulty of collecting physical address documents when the risk profile didn’t justify it. This amendment brings the law more in line with how organisations operate, supported by sector submissions including work from Lyn McMorran and the Financial Services Federation.

It’s a shift toward a more risk-based, proportionate approach — something long requested by many associations.

More Time for Reporting Obligations

Two further changes aim to improve reporting quality and practicality:

• Prescribed Transaction Reports (PTRs) now have a longer timeframe for submission.
• Suspicious Activity Reports (SARs) also have extended submission times.

For organisations working alongside AML-regulated providers — or operating within regulated settings themselves — this should ease reporting pressure and support more accurate, complete information.

Clarification on “Occasional Transactions”

Another helpful change clarifies the definition of “occasional transaction.”
Cheque deposits made at a registered bank or non-bank deposit taker are now excluded from this definition.

This removes ambiguity and helps prevent organisations being captured by rules not intended for low-risk, routine actions.

Why These Changes Matter for Associations

Many associations may not be directly captured by the AML/CFT Act, but often work alongside sectors that are. Others have members affected by changing compliance expectations.

These amendments demonstrate a move toward:

• More practical compliance requirements
• A better fit with how organisations actually operate
• Clearer proportionality and risk focus

They also show that sector feedback is being taken seriously — especially where compliance obligations have become unnecessarily burdensome.

What Happens Next

The Ministry of Justice will update formal guidance shortly. Until then, the amendments apply immediately.

If you or your members need further detail, the AML/CFT Programme Team can be contacted at aml@justice.govt.nz.

View the ministerial press release.

The amendments included in the Statutes Amendment Bill:

• clarify that address verification is not required for standard customer due diligence and only required under enhanced due diligence
• extend submission timeframes for Prescribed Transaction Reports
• extend submission timeframes for Suspicious Activity Reports
• clarify that cheque deposits at registered banks or non-bank deposit takers are excluded from the definition of “occasional transaction”