On 4 September 2025, the Department of Internal Affairs released new guidance for hotels, motels, and other accommodation providers who also offer currency exchange services.
The guidance sets out what these businesses must do to meet their obligations under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009. While accommodation itself isn’t captured by AML/CFT rules, the moment you provide foreign exchange, you become a reporting entity, and that brings specific compliance requirements.
So why does this matter? Many providers don’t see themselves as financial service businesses, but by offering currency exchange they face the same expectations as banks and money remitters. The new guidance makes it clear what’s required, helping you understand:
- What makes an accommodation provider a reporting entity.
- The types of risks you need to consider.
- Your obligations for customer due diligence and record-keeping.
- How to update your AML/CFT programme to stay compliant.
If you’re in this space, the guidance is well worth a read. It not only helps reduce the risk of getting caught out in an audit but also shows you how to build processes that are practical and fit for your business. You can read the DIA guidance here. If you’d like advice on what it means for you, get in touch – we’re here to help.