The Department of Internal Affairs

Department of Internal Affairs | Te Tari Taiwhenua

Building a safe, prosperous and respected nation



 

Information for High Value Dealers

Prohibited cash transactions for specified high value goods

From 11th May 2023 any person in trade/business that buys or sells any of the following high value goods are prohibited from doing so by a cash transaction of $10,000 or more:

  • Jewellery
  • Watches
  • Gold, silver, or other precious metals
  • Diamonds, sapphires, or other precious stones
  • Motor vehicles (within the meaning of section 6(1) of the Motor Vehicle Sales Act 2003)
  • Boats/ships (within the meaning of section 2(1) of the Maritime Transport Act 1994)

This prohibition was introduced under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT Act). It makes it harder for criminals to use or move cash anonymously through the purchase or sale of these high value goods.

There are civil and criminal penalties if you do not comply with this prohibition.

Note: The prohibition also applies to related cash transactions if the total value is $10,000 or more. For example, if there are two or more cash payments on different days towards the same purchase, such as on layby, the total must not exceed $10,000. Bearer-negotiable instruments, such as cheques, are also subject to the prohibition (including related transactions).

Changes for high-value dealers under the AML/CFT Act

Currently, some persons in trade/businesses that buy or sell the specified high value goods are caught as “high-value dealers” under the AML/CFT Act.

As high-value dealers, these persons/businesses are required to undertake customer due diligence and report prescribed transactions when carrying out cash transactions for customers of $10,000 or more. However, with the new prohibition now preventing these transactions, these persons in trade/businesses will no longer be a high-value dealer under the AML/CFT Act and will not have to comply with these requirements.

High-value dealers in other goods

From 11th May 2023 you will still be considered a high-value dealer under the AML/CFT Act if you carry out cash transactions of $10,000 or more, in the ordinary course of business, and you are dealing in any of the following items:

  • Paintings
  • Prints
  • Protected foreign objects (within the meaning of section 2(1) of the Protected Objects Act 1975)
  • Protected New Zealand objects (within the meaning of section 2(1) of the Protected Objects Act 1975)
  • Sculptures
  • Photographs
  • Carvings in any medium
  • Other artistic or cultural artefacts

If so, your obligations under the AML/CFT Act will continue to apply in the same way.

It is your responsibility to ensure all your business activities comply with these new requirements.

If you are a high value dealer under the AML/CFT Act and require further information regarding the new prohibition, please contact the Department of Internal Affairs at amlcft@dia.govt.nz.

Customer due diligence

In this section:

Amended Identity Verification Code of Practice 2013

On 10 October 2013 an Amended Identity Verification Code of Practice was gazetted under section 64 of the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT Act). The amendments come into force on 1 November 2013.

Guidance on Expired Passports for Identification in Customer Due Diligence

This factsheet outlines how to use expired passports for identification purposes in accordance with the Amended Identity Verification Code of Practice 2013:

Providing Proof of Identification

When engaging in cash transactions equal to or above NZD10,000, HVDs need to ask their customers to provide proof of identification to be able to comply with the AML/CFT Act. The following CDD information sheets can be used to help your customers understand why they are being asked to provide proof of identification.

Customer Due Diligence information sheet: proof of identification

This information sheet is available in English, Maori, Chinese, Samoan and Hindi:

Factsheet: Birth Certificates with Redacted Information

This document outlines the position the AML/CFT Supervisors have taken on birth certificates with redacted information (other than name and date of birth) as a form of identification under the Identity Verification Code of Practice.

Statement of Kiwi Access Card

This document outlines the position the AML/CFT Supervisors have taken on the kiwi access card as a form of identification for the purposes of Identity Verification Code of Practice.

Outsourcing Customer Due Diligence

Outsourcing CDD typically occurs during the onboarding process for a new customer. While these providers can provide a useful service, we want to remind reporting entities that outsourced CDD does not exist in isolation from their wider CDD procedures and obligations.

In the Ordinary Course of Business Guideline - Updated December 2017

This guideline is designed to help clarify the meaning of the phrase "in the ordinary course of business" in the definition of HVD in the AML/CFT Act:

This December 2017 update replaces the previous version published in 2012.

Designated Non-Financial Businesses and Professions and Casinos Sector Risk Assessment – December 2019

The Designated Non-Financial Businesses and Professions and Casinos Sector Risk Assessment (DNFBP SRA) is a review of the characteristics of the sectors covered by the AML/CFT Act - lawyers, conveyancers, accountants, real estate agents, high value dealers and the New Zealand Racing Board. The SRA is intended to help AML/CFT supervisors understand the money laundering and terrorism financing risks across these sectors and assist reporting entities by providing guidance on the specific risks and vulnerabilities relevant to their business.

NZ Police Financial Intelligence Unit (FIU)

The FIU collects, analyses and disseminates financial intelligence relating to suspicious transactions/activities, money laundering and the financing of terrorism. 

NZ Financial Intelligence Unit (NZ Police website)

The FIU has also released the National Risk Assessment (NRA) and a support document under the AML/CFT Act 2009. 

The NRA is designed principally for the use of the Ministry of Justice, AML/CFT supervisors, and the New Zealand Customs Service. The NRA may also be useful to reporting entities in understanding the broader picture of money laundering and terrorist financing risks at a national level.

The NRA can be found on the Police website.

Other Customer Due Diligence Guidelines

Beneficial Ownership Guideline (updated April 2024):

A key task in meeting the requirements of the AML/CFT Act is to identify and verify customers’ beneficial ownership arrangements. This guideline is to assist reporting entities in meeting the requirement to perform customer due diligence on the customer and beneficial owners of the customer.

Customer Due Diligence: Companies Guideline (updated April 2024):

Customer Due Diligence: Trusts Guidelines (updated May 2024):

Customer Due Diligence: Limited Partnerships Guideline (NEW April 2024):

Customer Due Diligence Fact Sheets:

These fact sheets are designed to help reporting entities understand the identification and verification requirements for different types of customers. The fact sheets should be read in conjunction with the beneficial ownership guideline.

On 9 July 2021 the Anti-Money Laundering and Countering of Financing of Terrorism (Requirements and Compliance) Amendment Regulation came into force. The companies and partnerships guidance assists reporting entities to understand and implement the requirement to undertake customer due diligence for nominee directors and nominee general partners. 

Enhanced Customer Due Diligence Guideline (updated April 2024)

This guideline assists you to conduct enhanced customer due diligence (EDD) on your customers under the Anti-Money Laundering and Countering Financing of Terrorism (AML/CFT) Act 2009 (the Act).

Designated Business Groups Guidelines

Designated Business Group - Scope Guideline (updated October 2022)

This guideline is designed to assist reporting entities to understand which obligations may be shared by members of a designated business group.

This October 2022 update replaces the previous version published in 2017.

Designated Business Group - Formation Guideline (updated October 2022)

This guideline is designed to help reporting entities understand the process for forming a Designated Business Group. This guideline also explains the process for notifying an AML/CFT supervisor about the formation of, or change to, a designated business group and provides the forms for doing so.

This October 2022 update replaces the previous version published in 2020.