The first is the levy. The AML/CFT Levy Regulations came into force on 8 October, and the levy applies from the year starting 1 July 2027. The Department of Internal Affairs collects it.
Not every entity pays. Banks and deposit takers carry most of it. Casinos and the TAB pay a share. A smaller slice falls on certain non-bank financial institutions and designated businesses. So check whether you’re in a leviable class and if you are, how your amount is calculated.
The second is the exemptions. Several class exemptions in the 2018 notice expire on 31 December 2026 and are not being renewed, including those covering:
- firms whose customers are licensed or specified managing intermediaries
- debt securities issued to specified subscribers through intermediaries
- tax pooling intermediary transactions
If you rely on one of these, the obligations previously covered by the exemption will apply from 1 January 2027.
From a systems perspective, levy amounts are worked out from figures such as assets, transaction values or customer numbers. Losing an exemption can mean collecting and verifying customer information your systems were never built to hold.
The real question is whether your systems already capture the right information, and how quickly you could produce it if a regulator asked.
If either change lands on your systems, happy to talk through what it means for your data and reporting.
