How AML CFT supervisors respond to non-compliance Recent Department of Internal Affairs (DIA) cases, including those involving Pagemark Limited and Lexington Trust Services Limited, show how enforcement powers are applied in practice. Supervisors are equipped with a range of measures to correct behaviour, protect the financial system, and maintain sector standards. This enforcement approach will sit within a changing supervisory structure. Under the announced single superviso

Recent enforceable undertakings accepted by the Department of Internal Affairs signal a clear shift in New Zealand’s AML CFT regime. These cases reinforce that foundational obligations must be met in practice, and that where compliance failures persist, regulatory action will follow even in the absence of proven money laundering.