The FMA has issued a guideline to assist issuers of securities and other participants in issues of securities in relation to the application of the AML/CFT Act 2009.  The guideline is intended to assist relevant market participants to determine whether or not they will be treated as a "financial institution" under the Act.  The guideline sets out the FMA's interpretation of "participating in securities issues and the provision of financial services related to those issues" in limb (a)(viii) of the definition of "financial institution", and gives a number of examples of application of that interpretation.  The guidance note is available here.