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Updated Designated Business Group guidelines released – act now 

What’s changed 
On 29 September 2025, the Department of Internal Affairs along with the Financial Markets Authority and Reserve Bank of New Zealand released updated guidelines on the scope and formation of Designated Business Groups (DBGs).

These guidelines introduce a new notification form and provide clearer rules on how reporting entities can elect, form, change, or terminate a DBG. For entities supervised by the DIA, DBG requests can now also be managed directly through AML Online. 

Why this matters  
Many FAPs and other reporting entities may be part of or considering a DBG to streamline compliance or reduce duplication. But without clarity and formal notification, there’s a risk of non-alignment with supervisory expectations, regulatory exposure, or ineffective group structures. 

With the updated guidelines, the supervisors have set clearer expectations – now it’s essential to make sure your DBG setup is valid, documented, and properly notified. 

What you should do now  

  1. Review the new guidelines and notification form on the DIA website.  
  1. Assess your current DBG structure (if any) – is it still appropriate under the new scope rules? 
  1. Prepare to notify your supervisor of any election, formation, change, or termination of a DBG, using the standalone form. 
  1. Ensure your documentation and internal policies reflect the changes, so your DBG is defensible if audited. 
  1. If supervised by DIA, use AML Online to manage DBG changes. 

Next steps 
If you operate or plan to operate as a DBG, now’s the time to review and act. Contact Strategi Compliance to ensure your DBG structure meets the updated supervisor expectations.

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