Country-specific guidance Current

Requesting beneficial ownership information from a corporate client

Knowing who's on the register isn't the same as knowing who owns and controls the company.

Onboarding a company client under New Zealand's AML/CFT Act means identifying more than the people named on the public register. This guide sets out a practical approach to asking for beneficial ownership information. It is general information, not legal or compliance advice.

Action plan

1 Ask who ultimately owns or controls the company, not just who's listed Customer due diligence extends to beneficial owners standing behind the named company, not only its registered directors.

DIA's guidance for AML/CFT reporting entities is explicit that customer due diligence includes identifying the beneficial owners of a corporate customer: the people who ultimately own or exercise effective control over it, not only the individuals named as directors or shareholders on the public register.

  • Ask the client directly who ultimately owns or controls the company
  • Don't treat the registered directors and shareholders as automatically the full picture
  • Document the ownership and control structure you're told, so it can be reviewed later

Done when: The company's beneficial owners have been identified and documented, not assumed from the register alone

DIA: AML/CFT FAQ for reporting entities
2 Apply both an ownership test and a control test New Zealand's framework generally treats a substantial ownership stake and effective control as two separate ways someone can be a beneficial owner.

New Zealand's AML/CFT framework is generally understood to treat a person who owns more than 25% of the customer, or who otherwise exercises effective control over it, as a beneficial owner. Ask about both: a shareholder below that threshold can still be a beneficial owner if they otherwise control the company, for example through voting arrangements or a controlling role in decisions.

  • Ask about ownership percentage and about who actually makes or controls key decisions
  • Don't rely on a single ownership threshold as the only test
  • Confirm the specific criteria your firm's own AML/CFT programme applies

Done when: Beneficial owners have been identified using both an ownership test and a control test

3 Verify each beneficial owner according to risk Once identified, a beneficial owner still needs their own identity verification, proportionate to risk.

Identifying a beneficial owner is a separate step from verifying them. DIA's guidance notes that beneficial owners should be verified according to the level of risk involved, using the same kind of reliable and independent evidence you'd use for an individual client.

  • Verify each identified beneficial owner independently, not just record their name
  • Match the depth of verification to the assessed risk of the relationship
  • Keep the verification evidence with your other customer due diligence records

Done when: Each identified beneficial owner has been verified proportionate to the assessed risk

See requesting identity documents from an individual client