New Zealand Department of Internal Affairs publishes guidance on AML/CFT obligations for online marketplaces with a NZD 10,000 threshold exemption

The New Zealand Department of Internal Affairs has released guidance to help online marketplace operators assess whether they are captured by the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 and what compliance steps apply as regulations for online marketplaces take effect from 1 June 2025. The guidance explains that AML/CFT requirements apply where an online marketplace handles funds associated with a sale, including by transferring money or value on behalf of a customer or issuing or managing a means of payment, and do not apply where the buyer pays the seller directly outside the marketplace’s payment ecosystem. It sets out a partial exemption under which most AML/CFT requirements apply only once a buyer or seller’s transactions exceed NZD 10,000 in any consecutive 12-month rolling period, including where transactions appear to be linked across one or more accounts, while suspicious activity reporting requirements continue to apply regardless of value. For customers above the threshold, full obligations apply, including customer due diligence (CDD), ongoing CDD and monitoring, and the need for a written risk assessment and AML/CFT programme. The Department also outlines expectations for identifying linked transactions using a risk-based approach, and notes that where a previously in-scope customer falls below the threshold, the remaining requirements cease to apply until the threshold is reached again.