Guidance Updates: Territorial Scope and Supervisory Framework – What you need to know

22 November 2019

The three Supervisors have recently updated two pieces of guidance. The Territorial Scope of the AML/CFT Act 2009 and the Supervisory Framework.

Territorial Scope Guideline

The guideline is designed to help you determine whether you have obligations under the Act. The updated guideline clarifies the territorial scope of the Act for financial institutions and designated non-financial businesses or professions (DNFBPs) including law firms, accounting practices, trust and company service providers and real estate agents.

Please note that one issue we have clarified is that if you are acting as a formation agent, or arranging nominees or trustees, in respect of New Zealand entities, you are providing that activity in New Zealand, even if the service is only provided to overseas persons and you will be considered a reporting entity.

If you are unsure if your activities are within territorial scope of the Act, please refer to the updated guideline or contact the Department at

Supervisory Framework

The Supervisory Framework sets out the shared objectives of the three AML/CFT supervisors in New Zealand. The changes made reflect the expansion of the AML/CFT legislation to include the new sectors and to ensure the document is up-to-date.

This document gives an overview of:

  • The four shared objectives of the supervisors
  • The AML/CFT framework in New Zealand including the Act, the Supervisors, The National Co-Ordination Committee and the Sector Supervisors Forum;
  • Regulations, exemptions, codes of practice and guidelines;
  • Supervision, including supervisor functions, supervisor powers and guiding principles; and
  • Compliance tools and techniques.