Date posted: 15/03/2018 7 min read

DIA publish AML guidance for accountants

Designed to help you work out whether the services you provide are covered by the AML/CFT Act and to help you prepare for 1 October 2018

In brief

  • Practical application guidance to help accountants comply is available from 29 March
  • The DIA will be covering the guidance in a complementary member-only webinar on 30 May
  • In June there will be a series of roadshow sessions for accountants throughout New Zealand

The Anti-Money Laundering and Countering Financing of Terrorism (AML/CFT) Amendment Act 2017 puts in place “Phase 2” of New Zealand’s AML/CFT laws. From 1 October 2018 it brings in accounting practices that provide certain services. Those that do are “reporting entities” for the purposes of the Act.

When the Law and Order Select Committee reported back on the AML/CFT Bill, it committed to the guidance being in place at least six months before the effective date. The government have kept to this commitment and 29 March is the date that the guidance for accountants will be released.

The Department of Internal Affairs (DIA) is the supervisor of all Phase 2 reporting entities and they wrote the guidance. The guidance clarifies how the DIA interprets certain aspects of the legislation in the context of the accounting profession. Firstly, to help accounting practices determine if they are a reporting entity, it provides examples of accounting services that are in scope of the AML/CFT Act. Secondly, it provides some useful examples of how to carry out customer due diligence (CDD) in practice.

The guidance also applies to reporting entities that provide similar services to an accounting practice, but may not identify as an “accountant”, such as bookkeepers and others who are not a member of a professional accounting body. They still come under the definition of an ‘accounting practice’ and in some cases a ‘trust and company service provider’. This ensures the policy is not anti-competitive.

As part of the government’s AML Advisory Group, we had the opportunity to provide feedback on a confidential draft of the guidance. The DIA are open to feedback on the guidance, and will make amendments where necessary, with the objective of continuous improvement.

Guideline: Accountants

Complying with the AML/CFT Act

View here


Guidance on how to file an annual report with DIA will also be released around the same time as the accountants’ guidance. The range of materials available to help accountants understand and prepare for the obligations under the AML/CFT Act is growing rapidly. Most notably, the recently released “Prompts and Notes” document which provides guidance on how to prepare a Risk Assessment and AML/CFT Programme.

Around June (dates to be confirmed), DIA will lead a series of roadshows throughout the country to help accountants come to grips with the work that needs to be completed before 1 October 2018.

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