All Customers to be Risk rated as at 1 June 2025

On 1 June 2025, all "Reporting Entities" in New Zealand will be required to implement a customer risk-rating system as part of their Anti-Money Laundering (AML) compliance, meaning every new customer will need to be assessed and given a risk rating based on their potential for money laundering activities; this is a key part of the updated AML/CFT regulations coming into effect on that date.

Key points about the June 2025 AML customer risk-rating:

New regulation:

This requirement is mandated by the latest AML/CFT legislation changes, which are being phased in with the final stage commencing on June 1st, 2025.

Risk-based approach:

The goal is to adopt a more risk-based approach to AML compliance by actively assessing the potential risk associated with each new customer.

Customer due diligence:

The risk rating will be determined during the customer due diligence (CDD) process when onboarding new clients.

Record keeping:

Reporting entities must maintain records of each customer's risk rating.

AML Partners recommends that Reporting Entities document the reasons for their risk rating. A short paragraph profiling the customer and reasons for the risk rating will inform both AML/CFT Supervisors and Auditors to how you arrived at your rating.