AML/CFT and Financial Crime – Property & Real Estate and Construction Lawyers
At the annual Property Law Conference held by The Law Association of New Zealand (TLANZ) in early 2026 Gary Hughes addressed the growing AML-CFT pitfalls facing property lawyers and trustees.
While AML/CFT requirements may be considered bane or pain for some lawyers, they remain a fact of legal life, and during 2026 are becoming only more complex in the property law space. Real Estate lawyers and those advising clients in the building and construction sector need to be aware of:
- Significant MoJ, DIA and Police changes afoot – culminating in major July 2026 amendments to the AML/CFT Act
- Structural reform to anoint the Department of Internal Affairs as sole super AML Supervisor, replacing the triple-headed FMA, Reserve Bank, and DIA framework that has existed since 2009
- A slew of new or updated guidance underway and soon to be released by the DIA in its new super role.
- As well as the financial crime cases that NZ Police keep bringing to highlight actual laundering risks in the construction/property developer sectors.
Neil Sands, a journalist for LawNews, was listening in and did a great article for TLANZ members, summarising some of the best comments. It discusses the feelings of reform fatigue in the AML/CFT changes, the legislative and regulatory reform submissions to Parliament, and increasing awareness of money laundering abuses taking place within real estate transactions.
In particular, Gary highlighted NZ Police Operation Beach involving construction companies, and Operation Martinez involving professional money launderers.
As part of that major July restructure, a new AML tax, described officially as a ‘Levy’ is going to be ushered in (payments to commence in 2027)
- Due to the fait accompli nature of the Levy decision, with almost no Ministry consultation, it led Gary to quip to the audience the issue was really dressed up for captive reporting entities as:
Now tell us, how much would you like to pay for the privilege of being regulated?
Extract from Neil Sands interview with Gary Hughes:
Property lawyers will be tired of the endless anti-money laundering reforms announced in recent years, but must maintain due diligence as authorities are adopting a tough approach to enforcement in the sector, AML/CFT specialist Gary Hughes has warned.
Addressing The Law Association of New Zealand (TLANZ) Property Law Conference on Thursday, Hughes admitted he was feeling reform fatigue too, saying keeping on top of AML/CFT changes had become “overwhelming”.
“It’s tricky when you get asked to talk about anti-money laundering and financial crime and property things – responses range from a grunt to a sort of downcast, frowny emoji, to a string of swear words,” he said.
Hughes said there was no doubt AML-CFT laws were needed to combat criminal elements in society, but added: “It’s getting more and more complex, and I’m somewhat dismayed at the successive waves of law reform.”
Lawyers in New Zealand have been subject to the anti-money laundering regime since 2018, and Hughes said tasks such as undertaking customer due diligence should be second nature by now.
Link to Article:
Link to TLANZ Committee:
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