Cardlink Systems and Kiwi Fuel Cards Limited

Date Made

Date signed: 2026-04-29

Sectors

Non-bank credit cards

Enacting statement

In accordance with section 157 of the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (“Act”), the Associate Minister of Justice hereby gives notice that she has granted the following exemption from the Act:

Ministerial Exemption: Cardlink Systems and Kiwi Fuel Cards Limited

Commencement date

This exemption comes into force on 2026-04-29

End date

This exemption will expire on 2031-04-30

Exemption

As the Associate Minister of Justice, and pursuant to section 157 of the Act, I exempt Cardlink Systems and Kiwi Fuel Cards Limited (CLKF) from the following provisions of the Act:

1. 1. Sections 10 to 39;
   2. 48A to 48C,
   3. 49 and 50 to 71 of the Act.

Conditions

This exemption is made subject to the following conditions:

1. 1. A fuel cardholder’s nominated bank account (for the purpose of payment of the fuel cardholder’s account) must be with a registered bank (as that term is defined in section 2(1) of the Reserve Bank of New Zealand Act 1989); and
   2. The fuel cards do not permit cash withdrawals or payments, are issued exclusively to entities or persons in New Zealand, and can be used only at a limited group of merchants within New Zealand.
   3. This exemption only applies to the following financial activities offered by Cardlink Systems and Kiwi Fuel Cards Limited:
      
      1. allowing cardholders to purchase fuel and other products and be invoiced at a later date.
   4. With the exception of six multinational corporations (“Corporations”) which make payments from outside New Zealand (and are known to the AML/CFT Supervisor), CLKF fuel card accounts are exclusively paid from an account with a New Zealand registered bank (as that term is defined in section 2(1) of the Reserve Bank of New Zealand Act 1989), or New Zealand issued credit/debit card. CLKF must notify the Department of Internal Affairs (DIA) within 10 working days if CLKF begins to accept payments from outside New Zealand from any payer other than the Corporations. For the avoidance of doubt
   5. CLKF is not required to notify the DIA if CLKF ceases to accept payments from outside New Zealand from any of the six Corporations.
   6. Cardlink Systems and Kiwi Fuel Cards Limited must inform the Ministry of Justice of any changes that may affect the exemption and/or conditions imposed by this written instrument within 10 days from when the change affecting the exemption occurs.

Statement of reasons

This exemption has been made for the following reasons:

1. 1. There is a low risk of money laundering and terrorism financing through Cardlink Systems and Kiwi Fuel Cards Limited because:
      1. The fuel card balances are paid via direct debit from a bank account with a registered bank or by cheque or credit card; no cash is introduced into the financial system.
      2. There is transparency in across transactions conducted between Cardlink Systems and Kiwi Fuel Cards Limited and its fuel cardholders.
      3. The average value of transactions is low.

Contact

Any person wishing to provide comment on this notice should contact the Anti-Money Laundering and Countering Financing of Terrorism Team at the Ministry of Justice by emailing amlcft.exemptions@justice.govt.nz