The AML Space

How AML CFT supervisors respond to non-compliance Recent Department of Internal Affairs (DIA) cases, including those involving Pagemark Limited and Lexington Trust Services Limited, show how enforcement powers are applied in practice. Supervisors are equipped with a range of measures to correct behaviour, protect the financial system, and maintain sector standards. This enforcement approach will sit within a changing supervisory structure. Under the announced single superviso

Recent enforceable undertakings accepted by the Department of Internal Affairs signal a clear shift in New Zealand’s AML CFT regime. These cases reinforce that foundational obligations must be met in practice, and that where compliance failures persist, regulatory action will follow even in the absence of proven money laundering.

This final article in the Insights trilogy examines the legal framework that gives New Zealand’s AML and CFT regime its force. It outlines how legislation translates international standards into enforceable obligations, and why understanding the law is essential to applying the regime with confidence, judgment, and proportionality.

This first article in an Insights trilogy explores why New Zealand has an AML and CFT regime. It examines the international context, the role of trust as a national asset, and why safeguarding system integrity matters in a small, connected economy.

This second article in the Insights trilogy examines how New Zealand’s AML and CFT regime operates in practice. It explores the risk based framework, the role of judgment, and the realities organisations face when applying obligations day to day with imperfect information.

This reflection traces my hesitant entry into AML work at a time when the profession viewed it with apprehension. What began as a practical decision gradually became a deeper commitment to safeguarding trust, integrity, and the values that underpin New Zealand’s institutions.