Under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT) certain businesses are required to put preventative measures in place to help detect and deter money laundering and countering financing of terrorism.


Phase 1 of Act has been in force since 2013. It applies to banks, casinos and a range of financial service providers. Phase 2 of the Act extends the AML/CFT regime to lawyers, conveyancers, accountants, real estate agents, sports and race betting, and businesses that deal in certain high value goods.


This requires operational and legal expertise. The AML/CFT Act requires:

  • correct risk identification,
  • adequate and effective policies, procedures and controls for customer due diligence, and ongoing customer due diligence,
  • account monitoring,
  • proper implementation, and
  • ongoing audits.

Inadequate or non-compliance with these obligations can give rise to significant business risks and legal issues if not properly managed. The penalties for non-compliance in the case of an individual, is either or both of the following:

  • A term of imprisonment of not more than 2 years
  • A fine of up to $300,000

For a firm, the penalty is, a fine of up to $5 million.


This may appear daunting. It does not have to be so.


Our panel of experts can help you to cost effectively manage all your AML/CFT Act compliance obligations.


This includes:

  • Preparing your AML/CFT risk assessment and programs,
  • Helping you to choose adequate cost effective software to automate some of your compliance obligations,
  • Post implementation review of your AML/CFT risk assessment and programs,
  • Ongoing AML/CFT Act advisory work, and  
  • AML/CFT related training and audits.

We can also represent you if you are currently or in the future faced with queries, audit or enforcement action by AML/CFT regulators. READ MORE

















(c) 2018 IR Legal Limited



Uddhav Kirtikar

Director, Compliance Plus 


Uddhav has a law enforcement background. He has practical experience in combating organised crime and terrorism. He has added to his practical experience through academic studies towards a Master of Strategic Studies from Victoria University of Wellington, focusing on issues around transnational organised crime and terrorism. He brings an in-depth understanding of regulatory compliance in New Zealand built over a period of 14 years working with New Zealand regulators. He spent 3 and a half years helping the Financial Market Authority (FMA) implement the AML/CFT Act. He was FMA’s lead writer for most of the AML/CFT guidelines published jointly by the FMA, Department of Internal Affairs and the Reserve Bank of New Zealand. He also assisted in designing templates and processes for the FMA when it commenced AML/CFT supervisory work. Uddhav’s strength was preparing for FMA, AML/CFT Act related documents in plain English. 

Patrick Goggin

Senior Consultant, Compliance Plus


Patrick has extensive experience leading compliance and auditing small medium to NZ’s largest enterprises in the Financial Sector. He has held senior Inland Revenue positions as Group Manager, Investigations & Advice, Manager Financial Sector and as CFO governing performance and business transformation. He has expertise in areas including audit, digital forensics, fraud and internationally with Australian, Canadian, and UK tax authorities and the OECD.  He holds a BBS, MPA (Exec), and is a fellow of Chartered Accountants.  

Ismail Rasheed

Director and Principal Solicitor, IR Legal


Ismail is a specialist lawyer. He has a law enforcement background in the investigation of white-collar crimes including international money laundering, counterfeit currency and travel documents. He was trained as a detective in India, UK, US, and at the Interpol Headquarters in France. He has a law degree from the University of Waikato. Before he started his own law practice he worked for the Inland Revenue for 16 years as a specialist tax lawyer and advised on complex tax issues, including tax avoidance, insurance taxation, issues involving Crown entities, tax disputes, binding rulings and the use of Commissioner’s powers by the Inland Revenue staff. READ MORE

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