Consultation on proposed AML/CFT infringement fees

The Ministry of Justice is seeking feedback on proposed fee levels for infringement offences under the future AML/CFT infringement scheme. The consultation was originally due to close on 30 September, but the deadline has now been extended to Friday, 16 October 2026.

The consultation relates to the Anti-Money Laundering and Countering Financing of Terrorism (Omnibus) Amendment Bill (the Bill), which includes provisions to establish an infringement regime for AML/CFT breaches. The Bill would allow regulations to set infringement fees of up to $20,000. Before any regulations are made, the Government is seeking feedback from businesses and individuals who may be affected.

The feedback will help inform the development of the regulations, including the level of fees attached to infringement offences.

Why is an infringement regime being introduced?

Infringement offences are intended to deal with relatively minor, straightforward offending without requiring matters to go through the courts. They are strict liability offences, meaning that the prosecution does not need to prove that a person intended to breach the law. The Ministry therefore considers it important that infringement fees are set at an appropriate level and are fair and proportionate to the corresponding offence.

The consultation document also notes that the AML/CFT Act does not currently provide the Department of Internal Affairs (DIA) with an efficient and proportionate way to respond to minor misconduct and low-level offending. At present, the DIA may have to rely on formal warnings or resource-intensive civil or criminal proceedings. A warning may not always be sufficient, while court proceedings may be disproportionate for relatively minor breaches.

The proposed infringement regime is intended to address this enforcement gap and provide the DIA with an additional response for lower-level non-compliance.

What is the Government seeking feedback on?

The Ministry is seeking views on:

• the proposed approach to setting infringement fee levels;

• the potential impact of the proposed fees;

• the proposed fees and options set out in the consultation; and

• any other information or perspectives that should be considered.

The consultation does not cover the design of the specific infringement offences themselves, or whether particular infringement offences should be introduced or removed. It is focused specifically on the proposed fee levels.

The proposed fee

The Ministry is proposing a fee matrix with different tiers and corresponding infringement fees. It has put forward two options and, as part of the consultation, is seeking feedback on which approach would be more appropriate.

From “Discussion Document Infringement fees” at pages 11 and 15.

What’s next

Get in touch if you have any questions about the consultation.

Submissions close on Friday, 16 October 2026.