DIA enters into Enforceable Undertaking with Pagemark Limited

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17 October 2025

The Department of Internal Affairs has entered into an enforceable undertaking with Pagemark Limited, a trust and company service provider, under section 81 of the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (the Act).

The decision followed findings of non-compliance, including failures to:

  • undertake and maintain a compliant risk assessment,
  • maintain an adequate AML/CFT compliance programme, and
  • submit Prescribed Transaction Reports (PTRs) to the NZ Police Financial Intelligence Unit.

The enforceable undertaking reflects the Department's response to serious non-compliance. It also highlights risks associated with services like company formation and registered office provision and reinforces the importance of having AML/CFT processes that are well understood and effectively applied.

Read the full media release here: DIA enters into Enforceable Undertaking with Pagemark Limited over non-compliance with anti-money laundering rules (DIA Press Releases)