Our joint submission reiterates our very strong view that the AML/CFT system benefits New Zealand as a whole and should be funded wholly by government, while acknowledging  the decision of the government to recover some of the costs of the AML/CFT system from industry.

It also highlights the AML/CFT compliance costs already incurred by entities to meet their AML/CFT obligations. The submission raises our concern that the Bill grants the responsible Minister the power to determine through regulations the portion of costs to be met by the Levy and that the consultation document does not outline the projected Crown spend, making it difficult to assess whether the proportion of the overall levy costs attributable to a levy is appropriate.

We recommend that the method of calculating a levy enables specified reporting entities to budget for the levy at the commencement of each financial year, with any shortfall or excess borne by the Crown and the method amended for future years as required.