Centrapay Limited

Date Made

Date signed: 2026-06-29

Sectors

Payment providers

Enacting statement

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

Ministerial Exemption: Centrapay Limited

Commencement date

This exemption comes into force on 2026-06-29

End date

This exemption will expire on 2031-06-29

Exemption

As the Associate Minister of Justice, and pursuant to section 157 of the Act, I exempt Centrapay Limited (“Centrapay”) from the following provisions of the Act: 

1. 1. Sections 10-21
   2. Section 22(1)(a) and (b)
   3. Section 22(2) to (6)
   4. Sections 31-39
   5. Sections 49-71  

Conditions

This exemption is made subject to the following conditions:

1. 1. This exemption applies to Centrapay’s Payap Service in relation to its customers (the merchants); 
   2. Transactions must be monitored to identify suspicious activity and high-risk situations where enhanced customer due diligence is required as set out in section 22(1)(c) and (d) of the Act;
   3. Centrapay is required to conduct enhanced customer due diligence if triggered under section 22(1)(c) or (d) of the Act;
   4. Where a transaction is relevant to a suspicious activity, section 49 and 49A of the Act apply;
   5. All settlement and fund transfers must be executed via BNZ as the settlement bank;
   6. Only accounts held at New Zealand financial institutions are used to pay or received funds from the purchase; 
   7. Payments can only be made using a debit card or bank account; 
   8. This exemption applies only to purchases by scanning a QR code of a merchant that has a retail store; and
   9. Centrapay must inform the Ministry of Justice of any changes that may affect the exemption within 10 working days from which the changes affecting the exemption occur. 

Statement of reasons

The exemption has been made for the following reasons: 

1. 1. There is a low risk of money laundering and terrorism financing through Centrapay because:  
      1. Centrapay’s Payap Service is only available for purchases by scanning a QR code of a merchant that has a retail store.  
      2. Both the purchaser’s bank and the merchant’s bank must be New Zealand banks which mitigates the risks associated with international movement of funds.
      3. All banks involved have some visibility of both the source and recipient of funds which provides some AML/CFT controls across the transactions.
      4. All refunds or dispute resolutions are managed directly by the banks and parties involved. 
   2. The obligations imposed on Centrapay would be disproportionate given the low risk of money laundering and terrorism financing.  
   3. The exemption granted has a low impact on the integrity of the anti-money laundering and countering financing of terrorism system in alignment with section 157 of the Act.  

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.