Setting up a New Zealand business that uses cryptocurrency for payments, conversion or transfers starts with classifying the services it provides. Gofaizen & Sherle helps crypto payment providers assess whether they need to register as a financial service provider (FSP) in New Zealand, prepare the application, and identify any separate authorization their activities require.
Payment and value transfer with cryptocurrency functionalityBusiness model
As FSP on the Financial Service Providers Register (FSPR), administered by the Companies OfficeRegistration
Department of Internal Affairs (DIA), which oversees anti-money laundering and countering financing of terrorismAML/CFT supervision
Financial Markets Authority (FMA) licensing where the activity requires itSeparate licensing
A qualifying director and physical registered addresses for a New Zealand companyCompany setup
On requestProfessional fee
The Right Fit for Your Business
Positive Signs
Your business can show who receives, converts, holds and transfers customer funds.
You can show where your clients and operations are based and explain your New Zealand connection.
Your team can implement customer checks and transaction monitoring before launch.
Warning Signs
Your intended customers are exclusively offshore, or you would operate from overseas serving only New Zealand wholesale clients.
You expect incorporation or a registered address by itself to establish a sufficient local connection.
You plan to hold repayable balances or offer tokens with investment rights.
Use these signs to guide your assessment.
Regulatory Scope for Crypto Payments and Transfers
Classify services by what they do with customer assets.
Payments and transfers
Cryptocurrency exchange
Wallets and custody
Brokerage and token-based products
New Zealand has no general cryptocurrency license or dedicated payment service provider or e-money license. The FSPR lists registered FSPs and their services. Registration carries no endorsement.
Subject to exceptions, you must register if you serve New Zealand clients above the applicable threshold, provide financial services as an AML/CFT reporting entity, or provide services that trigger a separate statutory licensing or registration requirement.
Taking deposits or accepting other repayable funds outside a genuine trust arrangement may trigger debt-security or deposit-taking rules. Tokens representing debt, equity, interests in managed investment products or derivatives can also bring additional rules into scope. Regulated retail offers may require licensing and disclosure. Wholesale or offshore exceptions leave the rules against misleading or deceptive conduct in place.
We trace who receives, holds and transfers the funds.
01
Service Classification
Classify services using client markets, custody, transfers and token rights.
02
Company Structure
Review ownership, director eligibility and registered addresses.
Identify the company documents and director consents to prepare.
03
AML/CFT Policies
Help prepare the written risk assessment, program and policies for customer checks and transfers where required.
04
Application Support
Help prepare filings and responses to authority requests, and check dispute scheme requirements.
Cost and Services
Payment and Transfer Setup Support
Price on request
service and company structure assessment
preparation of applicable AML/CFT policies and application materials
support with authority follow-up on the agreed application
The quote lists professional fees, official fees, levies and third-party charges separately.
How the Setup Works
Step1
Classify the Services
You describe the services. Gofaizen & Sherle identifies the applicable requirements.
Step2
Set Up the Company and Controls
You approve the structure and arrange signed consents. For a New Zealand company, appoint at least one director who lives in New Zealand or lives in Australia and currently directs an Australian-incorporated company. Gofaizen & Sherle helps prepare company documents and applicable AML/CFT policies.
Step3
Prepare the Filing
Gofaizen & Sherle helps prepare the application. The Companies Office reviews the FSPR application before payment. If you apply only for licensed services, obtain authorization for at least one before the Companies Office completes FSPR registration.
Step4
Answer Follow-up
You supply any information the authority requests. Gofaizen & Sherle helps you respond. Launch once you meet the applicable conditions.
What We Need From You
Services and Token Rights
Share your business plan or service description and the agreements that explain what customers receive.
Clients and Markets
Identify customer locations, retail or wholesale status and where you intend to operate.
Company and Ownership
Provide an ownership chart, director details and proposed registered addresses.
Funds, Technology and Controls
Share fiat and crypto flow diagrams, custody arrangements, platform contracts and existing AML/CFT policies.
Our expertise
Why Gofaizen & Sherle?
We combine legal, regulatory and technical expertise to support asset tokenization projects from initial assessment to implementation.
01Corporate structuringCompany formation and cross-border business setup.
02Financial regulationsApplication preparation and regulator-facing documentation.
03Compliance & GovernanceAML/CTF frameworks and post-authorisation support.
Set your launch date after checking which reviews your business needs.
Company Incorporation
You have 20 working days after reserving the name to complete incorporation, including filing signed consents.
FSPR Checks
Required criminal-history checks take 2–5 working days after payment.
Separate Decisions
Separate authorizations and bank reviews follow their own schedules.
New ZealandCryptoRegulatory Framework
New Zealand Cryptocurrency Regulatory Framework
The Companies Office handles incorporation under the Companies Act 1993 and administers FSPR under the Financial Service Providers (Registration and Dispute Resolution) Act 2008. Incorporation creates the company. FSPR registration records the financial services it provides. An exchange that converts cryptocurrency for customers may provide a value transfer service and should check whether it must register.
Under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009, reporting entities must build their written AML/CFT program around the risks of their own operations. For a payment or exchange business, that means looking at how customers fund transactions, where the money goes and which transfers warrant closer scrutiny.
FMA assesses token rights and platform activities under the Financial Markets Conduct Act 2013. An exchange that lists tokens qualifying as financial products may need a market operator license. Accepting repayable customer funds outside a genuine trust arrangement may also trigger deposit-taking rules overseen by the Reserve Bank of New Zealand.
Current Regulatory Status
Law
What It Means for the Business
Companies Act 1993
New Zealand companies need a qualifying director and physical registered addresses.
Financial Service Providers (Registration and Dispute Resolution) Act 2008
Assess FSPR eligibility and retail dispute scheme requirements.
Anti-Money Laundering and Countering Financing of Terrorism Act 2009
Reporting entities must implement the required controls.
Financial Markets Conduct Act 2013
Check product classification, licensing and disclosure where applicable.
Ongoing Compliance Obligations
Plan for annual filings and applicable controls.
FSPR. Confirm your registered details and services annually and keep required information current.
AML/CFT. A reporting entity needs a compliance officer and a written risk assessment and program. Monitor relationships and verify customer and beneficial owner identities through customer due diligence (CDD). Check source of funds or wealth where enhanced CDD requires it. Keep AML records for at least five years, with the start date depending on the record type.
Travel rule. Since June 1, 2024, relevant virtual-asset transfers have required accompanying information. Duties depend on the role and counterparty, including for some transfers below NZD 1,000.
Reporting and audit. Submit suspicious activity reports when suspicion arises regardless of value, file prescribed transaction reports when their separate triggers apply and meet annual AML reporting duties. Arrange an independent audit every three years, or four if DIA notifies you, and whenever DIA requires one.
The reporting entity remains responsible for outsourced compliance work. Missed controls and unlicensed activities can trigger enforcement.
Taxation
Inland Revenue (IRD) treats cryptoassets as property. Income from selling, trading or exchanging them is generally taxable. Most companies pay income tax at 28% of taxable profit. Buying and selling qualifying cryptoassets is excluded from goods and services tax (GST). Check the treatment of services, non-fungible tokens (NFTs) and mining separately.
The Crypto-Asset Reporting Framework (CARF) requires in-scope reporting crypto-asset service providers with a New Zealand connection to collect reportable data from April 1, 2026, and retain records for seven years.
Local Connection, Retail Clients and Market Access
The overseas FSPR route excludes providers with only offshore clients or, for overseas providers, only New Zealand wholesale clients.
If you must join a dispute resolution scheme (DRS), record membership on the FSPR within ten working days of registration.
Check local rules before marketing to or accepting customers abroad.
Confirm Applicability Before Launch
Confirm who holds customer funds or keys, which company contracts with customers and whether the payment or token creates a repayable balance or investment right. Give the bank or payment partner a flow-of-funds diagram, ownership information and relevant registration or license records.
No. New Zealand has no general cryptocurrency license. Depending on the services it offers, a crypto payment business may need to register as FSP and comply with AML/CFT requirements. A separate license may be required for certain activities, such as operating a financial product market.
Does FSPR registration cover overseas markets?
No. FSPR registration confers no overseas authorization.
Is crypto income always taxed at 28%?
The 28% rate applies to most companies. Individuals follow separate income tax rules.
Do stablecoins always need an FMA license?
Check the token’s rights and the services performed. Licensing is assessed individually.
When does a dispute resolution scheme apply?
Retail financial services generally require membership in an approved scheme, subject to statutory exceptions. The scheme handles customer complaints.
Must a director live in New Zealand?
A director who lives in Australia can qualify. Provide the Australian Company Number (ACN) of the company they direct.
How long does the application take?
The total varies with review and follow-up. Unfinished online applications expire 30 working days after you start them.
Will registration secure a bank account?
No. The bank decides after its own due diligence.
Does the Travel Rule cover self-hosted wallets?
DIA guidance excludes transfers without another virtual asset service provider from wire-transfer rules. CDD can still apply to business relationships, occasional transactions of NZD 1,000 or more, linked transactions or suspicion.
Can the program designer audit it?
The auditor must be appropriately qualified and independent of developing the risk assessment or establishing, implementing or maintaining the AML program.
When is the first CARF report due?
In-scope providers must report by June 30, 2027, for April 1, 2026, through March 31, 2027.
Gofaizen & Sherle has successfully implemented all the tasks related to the settlement of legal part (company formation and VASP license application) of our exchange whitebit.com.
Services Provided: End-to-end support with company share transfers in Lithuania and the USA (Montana), corporate account opening, AML/KYC policy development, regulatory compliance for FNTT and FinCEN, MICA licensing advisory, HR recruitment for C-level and AML roles, and payroll accounting services.
By clicking “Accept”, you agree to the storing of cookies and similar technologies on your device to enhance site navigation, analyze site usage, offer certain functionalities and assists in our marketing effort. Strickly necessary cookies are always active.
Our experts will tell you how to do it as quickly and easily as possible.
By clicking the button, I confirm that I have read the privacy policy and consent to the collection and processing of my personal data in accordance with the GDPR rules.
Thank you
Thank you for reaching us. Our team is working on your request, and we will contact you soon.