Country-specific guidance Current

New Zealand Companies Office identity verification for company clients

A useful starting point, not a substitute for verification.

The Companies Register can help you identify who's behind a company client, but it doesn't verify them for you. This guide sets out what that distinction means in practice. It is general information, not legal or compliance advice.

Action plan

1 Use the Companies Register to identify, not to verify The register helps you work out who's involved -- it doesn't confirm they are who they say they are.

Department of Internal Affairs guidance notes that where your customer is a New Zealand incorporated company, the online Companies Register may assist you in conducting customer due diligence by helping you identify the directors and shareholders who may be beneficial owners of your customer.

  • Search the Companies Register to identify a company client's directors and shareholders
  • Use this to identify who may be a beneficial owner needing further due diligence
  • Treat this as an identification step, not a verification step

Done when: The Companies Register has been used to identify the company client's directors and beneficial owners

DIA: AML/CFT FAQ for reporting entities
2 Still verify the individuals independently, according to risk The register assists identification; it doesn't complete the job on its own.

The same guidance is explicit that using the register doesn't remove your firm's obligation to verify the identity of the individuals identified as beneficial owners, according to the level of risk involved. Independently verify these individuals using your firm's own verification methods.

  • Verify each identified beneficial owner independently of the register listing
  • Match the depth of verification to the assessed risk of the relationship
  • Don't treat a register match alone as completed verification

Done when: Identified beneficial owners have been independently verified, proportionate to risk

See New Zealand AML/CFT Act client due diligence overview
3 Keep the register search itself as part of your evidence The identification step is worth recording, even though it isn't the verification step.

Because the register search is a genuine part of how you identified who needed further verification, keep a record of the search itself, including when it was done and what it showed, alongside the independent verification that followed.

  • Keep a record of the register search, including the date and what it showed
  • Keep this alongside the independent verification evidence for each individual
  • Don't discard the register search once independent verification is complete

Done when: The register search and the independent verification that followed are both kept as evidence