Gary was interviewed for two publications on Anti-Money Laundering and financial crime topics during the first quarter of 2025.
Regulation Asia magazine picked up on the new NZ Police National Risk Assessment recently released, the first such updated assessment published since 2018-19.
An important document for all AML reporting entities, and to set the overall direction of Police priorities, its expanded format continued to identify the 3 most prevalent criminal threats for New Zealand being: fraud (including cybercrime), drug dealing, and trans-national money laundering moving illicit proceeds from offshore into NZ assets.
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NZ AML Police new NRA Regulation Asia article with Nathan lynch March 2025
“New Zealand’s latest National Risk Assessment should act as a trigger for organisations to review their risk assessments, internal systems and controls, writes Nathan Lynch.
Banks and other reporting entities will need to review their AML/CFT compliance frameworks in view of New Zealand’s latest National Risk Assessment (NRA), which is the first such update in more than five years. The New Zealand Police Financial Intelligence Unit (FIU) has detailed a rapidly changing threat landscape, with fraud and cybercrime rising amid more traditional risks such as drugs and transnational organised crime. The latest risk assessment is also the first to include a nation-wide Proliferation Financing Risk Assessment, which is now a requirement from the Financial Action Task Force (FATF).”
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“New Zealand financial crime barrister Gary Hughes, of Britomart Chambers, endorsed this recognition of the scale and impact of fraud. “Although this Police NRA document is many months overdue, it is pleasing that it finally recognises what those of us in the field — or those poor individuals hit by ever-increasing scams — have known for years. Fraud deserves to be in the top-tier of risks and criminal threats. We need to have all the guns of the anti-money laundering system trained on it,” Hughes said.”
Separately, the LawNews NZ magazine has been following development of a large number of amendments to the AML-CFT Act 2009, including AML address verification. These changes are rolling out through various Parliamentary Bills, and LawNews talked to Gary after he led an important submission that was well-received by the Governance & Administration Select Committee.
In his role as Convenor of The Law Association of NZ (TLANZ) specialist AML/CFT committee, Gary leads a team that has provided input throughout the Ministry of Justice’s drawn out process during 2024-25, and earned praise from MPs on the Select Committee for their detailed and no-nonsense submissions.
TLANZ was previously known as the Auckland District Law Society, but has grown to almost 8000 members and spread out nationwide in recent years, leading to its recent rebrand.
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“The need to reform anti-money laundering rules was on the agenda at a recent parliamentary select committee hearing, with a government MP acknowledging that there’s “a lot of nonsense” in the current regime.
National MP Stuart Smith’s frank remarks came as the Governance & Administration Committee in late January discussed a submission from The Law Association of New Zealand (TLANZ) on proposed AML changes contained in the Statutes Amendment Bill.
Barrister Gary Hughes, the convenor of TLANZ’s AML committee, raised the issue of redundant requirements around address verification that businesses must comply with when engaging a new customer.
Hughes said the requirement resulted in massive compliance costs for businesses and brought little benefit for law enforcement due to the ease with which addresses can be faked or manipulated.
“This area of address verification has been one of the biggest pain points for everybody in the AML system for years and the ministry promised relief from the compliance burden,” Hughes told the committee.
“There was almost universal consensus that this would be a good thing on this particularly narrow point.”
Smith agreed, calling address verification “a real bone of contention” and pointing to broader issues in the AntiMoney Laundering and Countering Financing of Terrorism Act 2009.
“I know from experience that there’s a lot of nonsense in the AML [regime] that needs to be sorted out and [TLANZ’s submission] would go a long way towards doing that. So well done,” Smith said.”
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