The DIA has released two updated AML/CFT guidance documents for reporting entities:
· AML/CFT Programme Guidance.
· Enhanced Customer Due Diligence (ECDD) Guidance.
Both updates provide more detail on the DIA’s expectations and may affect parts of your AML/CFT framework, including programme wording, customer due diligence processes and staff training.
1. Updated AML/CFT Programme Guidance
The updated AML/CFT Programme Guidance reflects recent changes made through the AML/CFT Amendment Bill and provides more practical guidance on what an AML/CFT programme should cover.
The guidance reinforces that your programme must be based on your risk assessment and should include procedures, policies and controls that are both adequate and effective.
It also provides updated guidance across key programme areas, including customer due diligence, ongoing CDD and account monitoring, reporting, record keeping, reliance on third parties, outsourcing, training, vetting, compliance officer responsibilities, programme reviews and independent audits.
This matters because an AML/CFT programme should not be a generic document. It needs to reflect your business, your risks, your actual processes and the controls you use in practice.
Read the DIA release here: https://www.dia.govt.nz/AML-CFT-Updated-AML-CFT-Programme-Guidance-2026
2. Updated Enhanced Customer Due Diligence Guidance
The DIA has also published updated guidance on enhanced customer due diligence.
The updated guidance includes content on reduced verification requirements for trusts and determining whether a person is a politically exposed person (PEP), using a risk-based approach.
This is important because ECDD often requires reporting entities to make judgement calls based on the customer, structure, risk profile and information available. The updated guidance may help support more consistent decision-making and clearer internal procedures.
Read the DIA release here: https://www.dia.govt.nz/AML-CFT-Updated-guidance-for-Enhanced-Customer-Due-Diligence
What should you do now?
Start by reading the updated guidance and identifying which parts of your AML/CFT framework may be affected.
This may include:
· AML/CFT programme wording.
· Customer onboarding procedures.
· Trust processes.
· PEP checks.
· ECDD escalation points.
Once you have identified the relevant areas, update your policies, procedures, controls and training material as needed.
Remember to keep a record of what you reviewed, what you changed, and the reasons for any decisions made.
CPD support coming soon
Strategi is developing CPD modules to support implementation of three recent AML/CFT guidance updates:
· Identity Verification Code of Practice 2026.
· AML/CFT Programme Guidance 2026.
· Enhanced Customer Due Diligence Guidance 2026.
The modules are expected to be released by the end of this month and will help reporting entities and their staff understand what has changed and what may need to be updated in practice.