Global FinTech Guide
Country Name
New Zealand
KYC requirements
The know your customer or know your client (KYC) guidelines and regulations for financial services require that professionals try to verify the identity, suitability, and risks involved with maintaining a business relationship.

Legal affairs

National regulatory framework regarding AML and effective date of the regulations

AML in New Zealand is governed under the AML/CFT, and compliance is driven by the AML/CFT the Anti/Money Laundering and Countering Financing of Terrorism (Requirements and Compliance) Regulations 2011 (AML Regulations). The AML Regulations came into effect on 30 June 2013.

National regulator or relevant authority for AML controls

There are three (3) supervisors being RBNZ, the FMA and The Department of Internal Affairs.

Customer Due Diligence

Conduct of a typical KYC identification process

There are three (3), increasingly intensive, levels of CDD – simplified, standard and enhanced. Generally, business relationships will be captured under either standard or enhanced. Businesses assisting clients with activities captured under the AML/CFT are referred to as reporting entities. A risk assessment must be conducted considering (among other things) the client (and their ownership structure as applicable), the activity or activities they are engaging, a reporting entity to provide and the reporting entity’s relationship with the client. There is no express requirement to verify a client’s identity face to face (this is not always possible) but whether this has or can occur is often considered in an AML risk assessment.

Among other things, “reasonable steps” must be taken by a reporting entity to satisfy itself; i) that the CDD level relevant information they have acquired is correct; ii) of the identity of the beneficial owner of the client; and iii) that any information required by the AML Regulations has been sufficiently verified. Copies of IDs and proof address are sufficient and where the client cannot be met face to face those copies should be certified. Some reporting entities make use of biometric software to verify client identities where the client cannot meet them face to face.

Possibility to meet customer due diligence requirements by relying on third parties who are obliged by law themselves to comply with AML regulations

Yes, the AML/CFT provides for this.

Possibility to outsource customer due diligence by contract to other third parties who are not obliged by law to meet AML regulations and rely on these (e.g., WebID, IDnow, PostIdent)

Yes, reporting entities can either administer their own AML compliance or make use of a third-party provider.

Presence of a license or registration requirement for the third party in case of outsourcing customer due diligence

No licence is required.

Further questions

Entities that could be relied on specifically by law as a third party to comply with AML regulations (regardless of outsourcing)

Yes credit institutions
Yes financial institutions
Yes auditors, external accountants, and tax advisors
Yes notaries and other independent legal professionals
Yes other trust or company service providers
Yes estate agents
Yes other persons trading high-value goods
Yes providers of gambling services
Yes Reporting entities can rely on CDD performed by another reporting entity where they have mutual clients.



© 2022, Tompkins Wake. All rights reserved by Tompkins Wake as author and the owner of the copyright in this chapter. Tompkins Wake has granted to Multilaw non-exclusive worldwide license to use and include this chapter in this guide and to sublicense Lexis Nexis, a division of RELX Inc. and its affiliates certain rights to use and distribute this guide.

The information in this guide provides a general overview at the time of publication and is not intended to be a comprehensive review of all legal developments nor should it be taken as opinion or legal advice on the matters covered. It is for general information purposes only and readers should take legal advice from a Multilaw member firm.


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