Good AML/CFT is not simply about following rules. It is about understanding the story behind the money and exercising professional judgement. This article reflects on why source of funds, source of wealth, beneficial ownership and ongoing monitoring matter in practice, and why the most important question is often not, “Does this person look suspicious?” but “Do I understand the story behind the money?”

ASB has been ordered to pay $6.731 million, the largest AML/CFT penalty imposed in New Zealand to date, after admitting seven breaches of the AML/CFT Act. Much of the media coverage has understandably focused on the size of the penalty and the billions of dollars in transactions involved. However, for AML practitioners, the more important lesson lies elsewhere. The Court found that ASB's AML/CFT programme and transaction monitoring systems were inadequate for a prolonged peri

DIA’s enforcement history shows that AML/CFT breaches in the legal sector are not hypothetical. Foster & Milroy, Kidd Legal and PSB each provide a clear reminder that law firms must be able to show more than AML/CFT documents. They must be able to evidence that their risk assessment and compliance programme are current, understood, followed and working in practice.

Recent mortgage fraud typologies highlight a growing risk for law firms, where third party funding, inconsistent explanations, and transaction structures may signal activity that requires closer scrutiny.

This final article in the Insights trilogy examines the legal framework that gives New Zealand’s AML and CFT regime its force. It outlines how legislation translates international standards into enforceable obligations, and why understanding the law is essential to applying the regime with confidence, judgment, and proportionality.

This first article in an Insights trilogy explores why New Zealand has an AML and CFT regime. It examines the international context, the role of trust as a national asset, and why safeguarding system integrity matters in a small, connected economy.

This second article in the Insights trilogy examines how New Zealand’s AML and CFT regime operates in practice. It explores the risk based framework, the role of judgment, and the realities organisations face when applying obligations day to day with imperfect information.