Appeal against $1.125 million fine for offending against the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 – can a court remit or reduce an otherwise appropriate sentence to preserve the scope for an offender’s innocent creditors to be paid?

Qian DuoDuo Ltd v Department of Internal Affairs [2025] NZHC 3053 per O’Gorman J

Qian DuoDuo Ltd (QDD) is an Auckland foreign exchange and money remittance company and a reporting entity for the purposes of the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (the Act).

QDD ceased trading in March 2021. In June 2021, the Department of Internal Affairs brought criminal proceedings against it for contravening the Act. QDD pleaded guilty to a total of four representative charges for failing to report a prescribed transaction and failing to report activity. All were strict liability offences.