Renewal of the AML/CFT (Class Exemptions) Notice 2018

2026 Review of the AML/CFT (Class Exemptions) Notice 2018

Class exemptions relieve a class of reporting entities or a class of transactions from specified AML/CFT obligations. They are used where the money laundering and terrorism financing risk is low and applying the full obligations is out of proportion to the level of risk. 

Fifteen class exemptions set out in the Anti-Money Laundering and Countering Financing of Terrorism (Class Exemptions) Notice 2018 (the Notice) are due to expire on 31 December 2026. A substantive review of these class exemptions was carried out by the Ministry in 2026 in line with the 2025/26 amendments to the AML/CFT Act. 

In summary, the review resulted in the following decisions by the Associate Minister of Justice: 

• Ten class exemptions have been renewed for varying terms, some with amendments. The renewal term has been determined by the level of risk, to ensure a level playing field for businesses, and New Zealand's compliance with international Financial Action Task Force standards.  
• Five class exemptions will not be renewed because they are no longer fit for purpose. They will expire at the end of December 2026. The original need for the exemption will be addressed through primary legislation, or moved to risk-based assessments. Please see more detail in the table below.  

What are the amendments to the Notice?

The following table summarises the outcome of the 2026 review of each class exemption. View the Amendment Notice(external link)

Part	Class	Outcome of Review	Change from 31 December 2026
1	Bodies corporate and body corporate managers	Expiring 31 December 2028	Renewed for 2 years. The New Zealand Police Financial Intelligence Unit has identified potential risks that require further assessment. Renewing this exemption for a short term allows time for consideration of the potential risks and whether changes to the current exemption settings are justified, while taking into account the practical implications on the body corporate sector.
2	Public Trust, Māori Trustee, and trustee companies	Expiring 31 December 2031	Renewed for 5 years.
3	Service provided in relation to certain retirement schemes	Expiring 31 December 2031	Renewed for 5 years. Minor amendments to remove references that are no longer needed and modernise the Notice to improve clarity for reporting entities.
4	PAYE intermediaries	Expiring 31 December 2028	Renewed for 2 years. The New Zealand Police Financial Intelligence Unit has identified potential risks that require further assessment. Renewing this exemption for a short term allows time for consideration of the potential risks and whether changes to the current exemption settings are justified, while taking into account the practical implications on the sector.
5	Reporting entities who customers are licensed managing intermediaries	Expiring 31 December 2026	While Parts 5 and 6 will expire, DIA is providing a one-year good faith period from 31 December 2026. This period will provide time for internal policy work and consultation with impacted entities to consider the issues and appropriate options for more targeted regulatory relief.  The aim is to shift from a broad exemption model to a more targeted, accountable approach that maintains transparency over beneficial ownership while minimising unnecessary duplication of customer due diligence activities.
6	Reporting entities whose customers are specified managing intermediaries	Expiring 31 December 2026
7	Shared compliance officer for members of a designated business group	Expiring 31 December 2031	Renewed for 5 years.
8	Financial advice providers arranging for relevant services to be provided for retirement schemes	Expiring 31 December 2031	Renewed for 5 years. Amended clause 5(a) to explain how the conditions mitigate risk.
9	Specified employee security purchase schemes	Expiring 31 December 2031	Renewed for 5 years.
10	Specified securities investment schemes	Expiring 31 December 2028	Renewed for 2 years. The New Zealand Police Financial Intelligence Unit has identified potential risks that require further assessment. Renewing this exemption for a short term allows time for consideration of the potential risks and whether changes to the current exemption settings are justified, while taking into account the practical implications on the sector.
11	Casino loyalty schemes	Expiring 31 December 2026	Allowed to expire. Casino loyalty schemes are part of a casino’s broader products and services and should be managed as part of casinos broader AML/CFT obligations.
12	Statutory supervisors of retirement villages	Expiring 31 December 2031	Renewed for 5 years. Additional condition added to reflect that confirmation of source funds is required when a deposit is paid by someone other than the intended resident if the reporting entity considers that enhanced due diligence should apply due to the level of risk involved.
13	Designated issuers that issue debt securities to specified subscribers through intermediaries	Expiring 31 December 2026	Allowed to expire. The definition of ‘beneficial owner’ was clarified in an amendment to the Anti-Money Laundering and Countering Financing of Terrorism Act in 2026.
14	Transactions of tax pooling intermediaries (TPIs)	Expiring 31 December 2026	Allowed to expire. TPls are encouraged to apply for individual exemptions which will assess individual TPls and associated risks.
15	Barristers sole	Expiring 31 December 2028	Renewed for 2 years. The New Zealand Police Financial Intelligence Unit has identified potential risks that require further assessment. Renewing this exemption for a short term allows time for consideration of the potential risks and whether changes to the current exemption settings are justified, while taking into account the practical implications on the sector.
The following exemptions will be reviewed before their expiry date.
16	Transfers of excess tax	Expiring 27 July 2027	No change
17	New Zealand Financial Crime Prevention Network	Expiring 30 September 2027	No change
18	Operators of money or value transfer service and agents of operator	Expiring 31 December 2028	No change
19	Obligations of reporting entities in relation to person acting by electronic means, on behalf of customer	Expiring 31 December 2028	No change
20	Fraud Intelligence Exchange (FIX) Ecosystem	Expiring 1 November 2030	No change