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To apply for an AML/CFT exemption, you’ll need to provide detailed answers to all the questions in this section.
If you provide incomplete or insufficient information, we will contact you. If you fail to provide the missing information, your application will be rejected, and you will need to resubmit your application with more detail.
When preparing your application, you should consider the AML/CFT Act and information provided by government agencies about the risks your sector faces which is available from the AML/CFT supervisor.
The Anti-Money Laundering and Countering Financing of Terrorism (Supervisor, Levy, and Other Matters) Amendment Act 2026 came into force on 1 July 2026. This amends the exemption making powers by:
providing an alternative power for the Chief Executive of the Ministry of Justice to make an exemption notice under section 156E of the Act. Previously, businesses applied for Ministerial exemptions under section 157 of the Act. From 1 July 2026, businesses need to apply for a general AML/CFT exemption.
granting the AML/CFT supervisor the power to make notices in specific circumstances under section 156F of the Act. If you consider that one of the circumstances outlined in section 156F of the Act may apply to your business, please reach out to your AML/CFT supervisor at the Department of Internal Affairs.
Examples that were previously handled via exemption but may now be dealt with by the AML/CFT supervisor making a notice under section 156F of the Act include:
exempting a reporting entity from its obligation to obtain some or all of the information set out in section 27(1) in relation to a specified transfer or transaction.
declaring an entity or class of entities (whether domestic or overseas) to be eligible for inclusion in a designated business group.
You may want to seek advice from an independent AML/CFT expert or before applying.
What information should I include in an application?
Every application must include at least the following information.
Who is applying?
You will need to provide the following information:
the full name and address of the person/s seeking the exemption
corporate status and New Zealand Business Number (NZBN)
an overview of your business, including key office holder, major shareholders and any other material beneficial ownership information.
information on any associated corporate entities (parent or subsidiary) or unincorporated bodies, such as partnerships and unincorporated joint ventures.
Is the exemption for a reporting entity or a transaction?
The application should clearly state whether the proposed exemption relates to a reporting entity or class of entity, a transaction or class of transactions.
What do you want an exemption from?
Identify the provisions of the Act and/or regulations you are requesting to be exempt from, and any conditions of exemption you consider appropriate.
In what circumstances will the exemption apply?
Describe the reporting entity or transaction, and circumstances in which the exemption is sought.
Why are you seeking this exemption?
For each provision of the Act or regulations, explain why you want the exemption. You must also provide full and detailed reasons and evidence to support your statements.
Do you understand your existing money laundering and terrorist financing risks?
To help businesses understand the risks they face, the AML/CFT supervisor and the New Zealand Police Financial Intelligence Unit provide sector risk assessments and typology reports (a typology is an example of types of money laundering or terrorism financing).
You must demonstrate that you have considered the risks and issues facing your sector, product or service, how they relate to your application and how you will manage them.
Risks can also include deficiencies previously identified in your AML/CFT compliance or difficulties complying with previous exemptions. To show that you understand your risks, please demonstrate your awareness of these deficiencies and how you have addressed them to lower your risks.
What effects will the exemption have on your business?
Describe the effects an exemption will have on your business, and the relative costs and benefits. If the exemption is granted and you still face some money laundering and terrorism financing risks, provide evidence of how you will manage the risks.
What effects will your exemption on your competitors or other third parties?
Describe how your proposed exemption may affect other firms operating in your industry and describe any competitive effects. If the application is granted, discuss whether any third party’s rights may be adversely or favourably affected and, if so, how.
Is the exemption consistent with the intent and purpose of the AML/CFT Act and any regulations?
Please consider the following matters that underpin the AML/CFT system:
whether the proposed exemption is compliant with international obligations relating to anti-money laundering and terrorism financing
whether the exemption can be justified on the basis of a cost, benefit and risk analysis
whether the proposed exemption is compatible with Australian regulatory requirements
whether the proposed exemption is consistent with AML/CFT legislation in other Financial Action Task Force member countries.
Are there any precedent applications?
Please identify any existing exemptions similar to the exemption you are seeking. State how the existing exemption is similar to, and different from, your own circumstances.
Does your reporting entity undertake prescribed transactions?
The following questions help the Ministry of Justice to understand whether the reporting entity undertakes prescribed transactions as per Subpart 2A of the Act.
Please answer these questions with a YES or NO. If your answer is NO, please provide a brief reason why these transactions would not be conducted through the reporting entity.
In the course of the reporting entities' business:
does the reporting entity order international wire transfers to the value of $1,000 or more?
does the reporting entity receive international wire transfers to the value of $1,000 or more?
would a person conduct a domestic cash transaction of $10,000 or more through the reporting entity?
For definitions of the terminology used above, please refer to the Act and associated Regulations.
Does your reporting entity deal with strategic goods or countries of interest?
Dealing in certain goods, products, or services or with certain countries can materially affect a business’ risk profile. If your business deals in strategic goods, or has dealings involving countries of interest, please include this in your application and provide brief details.
This information is important to the Ministry of Justice’s assessment, but it does not automatically prevent an exemption from being granted. If you are unsure whether your business deals in strategic goods or with countries of interest, please refer to the guidance here:
Please ensure you provide relevant supporting material, including evidence to support your statements and conclusions.
Please include any assessment of the level of money laundering and terrorism financing risk related to your activities or the particular transactions that you are seeking an exemption for. Consider any relevant Financial Action Task Force publications or guidance, or guidance issued by the AML/CFT supervisor or the New Zealand Police Financial Intelligence Unit.
Statutory declaration
Your application must include a statutory declaration which states that:
the information provided is true and correct
the Ministry may seek and share information related to the exemption application, and
the applicant will inform the Ministry within 10 working days of any material change in circumstance that may impact the Ministry’s processing of the application.
The declaration must be signed by each applicant in front of a person who is authorised to take declarations (such as a Justice of the Peace).
If your exemption is due to expire and you want to extend it for another period, you must apply for a renewal.
Renewal applications are assessed in the same way as new applications. This means you must provide complete and up-to-date information about your business and the exemption you are seeking.
Information provided in a previous application will not automatically be considered.
You should clearly explain any changes since your last application, including:
changes to your business activities, products or services
changes to your business activities, services, customers, or delivery channels
changes to ownership or beneficial ownership
whether you are seeking changes to existing exemption conditions
how money laundering and terrorism financing risks may have changed
You should apply at least six months before your exemption expires.
Timeframes for processing, assessing and making decisions about applications depend on factors such as the number of applications we receive, how complex the application is, and the quality of information provided.
You must continue to comply with the AML/CFT Act until an exemption is granted.
Frequently asked questions
Do I need to apply for a renewal if I already have an exemption? Yes. Exemptions are granted for a specific period. If you want your exemption to continue, please apply for a renewal before it expires.
Renewal applications are assessed in the same way as new applications, so please provide full and up-to-date information.
When should I apply for a renewal? You should apply at least six months before your exemption expires.
Completing your renewal early avoids delays and reduces the need to fully comply with AML/CFT obligations while your renewal application is being considered.
Can I rely on information from my previous application? No. You must provide current and complete information each time you apply for renewal. You should clearly explain what has changed since your last application.
How long does it take to get a decision? Timeframes vary depending on:
how complex the application is
how complete the information provided is
how many applications are being assessed
Providing clear, well-supported information will help avoid delays.
Do I still need to comply with AML/CFT obligations while my application is being assessed? Yes. You must continue to comply with the AML/CFT Act unless and until an exemption is granted.
However, if you are concerned about any aspect of your obligations under the Act, we encourage you to engage with your AML/CFT Supervisor.
What information is important to include in the application? Applications should clearly explain:
what exemption is being sought
why the exemption is needed
the money laundering and terrorism financing risks involved
how those risks will be managed
who owns or controls the business (including beneficial ownership)
Providing supporting evidence will strengthen your application.
What happens if my circumstances change after I apply? You must notify the Ministry within 10 working days if there is a material change to your business that could affect your application or exemption.
Examples include changes to ownership, business activities, products, or risk exposure.