The Statutes Amendment Act 2024 came into effect on 27 November 2025 and makes changes to 42 Acts, including the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT Act) and the Credit Contracts and Consumer Finance Act 2003 (CCCFA). For reporting entities and financial advisers, these updates introduce new requirements and remove several long-standing pain points. Understanding the practical impact of these changes will help you keep your compliance obligations on track.
Key changes to the AML/CFT Act
The amendments introduce several updates that affect how reporting entities complete customer due diligence and meet ongoing AML/CFT obligations. The key changes include:
- Clarifying that address verification is no longer required for standard customer due diligence. It is now only required as part of enhanced customer due diligence, reducing a significant onboarding barrier for many reporting entities.
- Allowing greater flexibility when conducting enhanced customer due diligence by clarifying that address or registered office information, and information relating to source of funds or wealth, only needs to be verified according to the level of risk involved.
- Extending the timeframe for submitting prescribed transaction reports from 10 to 20 working days, providing additional time for higher quality reporting.
- Amending the exclusion for cheque deposits from the definition of “occasional transaction” so that it now only applies to deposits made at a registered bank or non-bank deposit-taker.
- Allowing law firms up to 5 working days, instead of 3, to provide suspicious activity reports to the Financial Intelligence Unit.
Changes to the CCCFA
The Act also makes several clarifications to streamline compliance for lenders. These include:
- Confirming that lenders do not need to keep records of their inquiries for applications that were declined or withdrawn.
- Clarifying that when two or more borrowers share the same postal address, sending a disclosure statement to any one of them is treated as disclosure to all.
What you may need to update
These amendments may require updates to your internal processes, documentation and training. AML/CFT reporting entities should review their AML/CFT Programme, onboarding checklists, enhanced due diligence procedures and staff training materials to ensure they reflect the new requirements for address verification, PTR timeframes and occasional transactions. Lenders may also need to update their CCCFA policies, disclosure procedures, templates and record-keeping practices to reflect the clarified obligations. If you use automated systems, CRMs or third-party tools, these may also require adjustment.
How we can help
If you are unsure how these changes affect your obligations, or what practical adjustments you may need to make, our team can work through the details with you and ensure your documentation remains compliant and defensible. If you would like to talk through what this means for you, just get in touch.