In accordance with section 157(6)(b) of the Anti-Money Laundering and Countering Financing of Terrorism Act 2009, the Associate Minister of Justice hereby gives notice that he has granted the following exemption from the Act.

Ministerial exemption: Snapper Services Limited (NZBN: 9429033715629)

1. As the Associate Minister of Justice, and pursuant to section 157 of the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (“Act”), I exempt Snapper Services Limited (“Snapper”) from the following provisions of the Act:
1. Sections 10–71 inclusive.
2. This exemption is in relation to public transport services paid for via the Account Based function of the Snapper Card.
3. In this exemption:
1. Public transport services means bus, cable car, train and ferry services.
4. This exemption is made subject to the following conditions:
1. this exemption applies where the total amount transacted through a Snapper Card is less than $10,000 in any consecutive 12-month period (this includes transactions made via both the Stored Value function and the Account Based function);
2. only accounts held at New Zealand financial institutions can be used to fund an Account Based transaction;
3. the exemption only applies to services provided in New Zealand. Snapper will need to ensure it complies with relevant legislation in other countries where it operates; and
4. Snapper must inform the Ministry of Justice of any changes that may affect the exemption and/or conditions imposed by this written instrument within 14 days from when the change affecting the exemption occurs.
5. This exemption has been made for the following reasons:
1. the Account Based function of the Snapper Card is low risk. It can only be used to pay for public transport services;
2. transactions made using the Account Based function on the Snapper Card are low value;
3. consumers cannot overpay their account beyond the pre-pay limit of $300 at any time and it is difficult for consumers to receive a refund;
4. only accounts held at New Zealand financial institutions can be used to fund an Account Based transaction. These financial institutions will undertake customer due diligence and have ongoing suspicious transaction reporting obligations; and
5. due to the low money laundering and terrorism financing risk associated with Snapper’s Account Based function and the significant compliance costs to Snapper that would arise from not granting this exemption, I consider that any benefits of requiring compliance with the Act are not justified by the associated costs.
6. This exemption came into force on 7 February 2018.
7. This exemption will expire on 30 November 2022.

Any person wishing to provide comment on this notice should contact the Criminal Law Team at the Ministry of Justice by emailing international.crime@justice.govt.nz.