AML/CFT Compliance

Compliance with Anti-Money Laundering and Countering Financing of Terrorism Act

In 2009, New Zealand passed a law called the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (the “AML CFT Act”). The purposes of the AML CFT Act are: to detect and deter money laundering and the financing of terrorism;

  • to maintain and enhance New Zealand’s international reputation by adopting recommendations issued by the Financial Action Task Force; and to contribute to public confidence in the financial system.

From 1 July 2018, the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 applies to Grimshaw & Co and other law firms. The Act will also apply to accountants from 1 October 2018 and real estate agents from 1 January 2019.


The purposes of the Act are:

  • to detect and deter money laundering and the financing of terrorism;
  • to maintain and enhance New Zealand’s international reputation by adopting recommendations issued by the Financial Action Task Force; and to contribute to public confidence in the financial system.

The Act requires Grimshaw & Co to assess the money laundering and terrorist financing risk we may face in our business and to identify potentially suspicious activity. To make that assessment we must carry out “customer due diligence” (“CDD”) on new and existing clients.

How the Act affects our clients

CDD requires us to collect information about a client’s identity (including full name, date of birth and address) and in some cases a client’s source of funds and/or wealth. For trusts, we need information about the trust, individuals connected with the trust such as the trustees and the trust’s source of funds and/or wealth.

We must also take steps to make sure the information we have is correct.

We already hold information about you as part of your engagement of us. Some of this information may meet the Act’s identity and verification requirements. However, in some cases we may need to ask you for further information and see documents such as a passport, a bank statement or utility bill.

We will let you know what we require the next time we receive instructions from you or when there is a material change in the nature and purpose of our relationship. We will work with you to make the process as simple as possible. We may not be able to proceed with your instructions until we have received all the necessary CDD information.