Date posted: 22/10/2026

Submission on AML/CFT Infringement Fees

Submission to the Ministry of Justice on the proposed Infringement Fees regime

Chartered Accountants ANZ is supportive of the introduction of the infringement regime as part of graduated and  proportionate enforcement. The operational approach should remain responsive to circumstances, and the supervisor should publish an enforcement policy explaining when it will use education, a warning, an  infringement notice, or stronger action. Except where deliberate conduct or repeated non compliance make it inappropriate, entities should ordinarily have an opportunity to correct  minor administrative breaches before an infringement notice is issued. Our submission supports option two as it is more proportionate to the seriousness of the conduct and seems consistent with the fees imposed under other comparable infringement fee regimes.