Notice Title

Ministerial Exemptions Under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009

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

Ministerial Exemption: Linc Technologies Limited

  1. As the Associate Minister of Justice, and pursuant to section 157 of the Anti-Money Laundering and Countering Financing of Terrorism Act 2009, I exempt Linc Technologies Limited (“Linc”) from the following provisions of the Act:
    1. Sections 10–21, 22(1)(a)–(b), 22(2)–(6) and 23–29.
  2. This exemption is made subject to the following conditions:
    1. The exemption only applies where Linc’s school customers are New Zealand schools; as defined by the Education and Training Act 2020.
    2. If any circumstances in section 22(1)(c) to (e) of the Act apply, Linc is required to conduct enhanced customer due diligence on its user customers.
    3. Linc must conduct suspicious activity reporting from section 22(1)(c) and (d) (Enhanced Customer Due Diligence) under circumstances where required.

Linc Technologies Limited must inform the Ministry of Justice of any changes that may affect the exemption and/or conditions within 10 working days from when the change affecting the exemption occurs.

  1. This exemption has been made for the following reasons:
    1. The system is to prevent overpayments; each payment is linked to a request for funds initiated by the relevant school and any refund will be linked to the cancellation of the event the funds were for.
    2. Linc’s customer use the New Zealand banking system to send or receive payments.
    3. Customers are New Zealand based school and their parents or caregivers, the verification of identification and address of the students and parents and caregivers.
    4. In subject to maintaining regulatory processes, school enforce a verification process of address and identity of parents and caregivers at the enrolment stage of the relevant student.
    5. All payments are cashless.
  2. This exemption comes into force on the day after the date I granted this exemption (17 February 2026).
  3. This exemption will expire five years from the date it comes into force.

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