New Zealand's Department of Internal Affairs has published guidance for hotels and other accommodation providers that offer currency exchange services, setting out how they should meet obligations under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009. It clarifies that accommodation providers offering currency exchange are “reporting entities” as financial institutions, but may be partially exempt from many requirements for currency exchange transactions (or a series of related transactions) that do not exceed NZD 1,000, while still needing to submit suspicious activity reports and keep records where relevant to suspicious activity reporting. The guidance explains that all AML/CFT requirements apply where currency exchange transactions exceed NZD 1,000, including customer due diligence and any prescribed transaction reporting, and that the NZD 1,000 threshold also applies to related or linked transactions as an anti-avoidance measure. It sets expectations for risk-based procedures to identify structuring and related transactions, and highlights practical controls such as collecting identity information, linking exchanges to a guest’s stay, maintaining records even below the threshold, separating currency-exchange cash from other floats, and monitoring patterns for escalation. It also reiterates that suspicious activity reports must be filed with the New Zealand Financial Intelligence Unit via goAML within 3 working days of forming a suspicion, and that accommodation providers offering currency exchange services must register on the Financial Service Providers Register.
Department of Internal Affairs 2025-09-04
New Zealand's Department of Internal Affairs issues AML/CFT guidance for accommodation providers offering currency exchange with NZD 1,000 threshold
New Zealand's Department of Internal Affairs has clarified obligations for hotels offering currency exchange under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009. As "reporting entities," they must comply with AML/CFT requirements for transactions over NZD 1,000, including due diligence and reporting. The guidance mandates risk-based procedures, suspicious activity reports within three days, and registration on the Financial Service Providers Register.