Country-specific guidance Current

Requesting identity documents from an individual client in New Zealand

A practical checklist for collecting identity evidence before you start providing a service.

Reporting entities under New Zealand's AML/CFT Act generally need to identify an individual client before starting a designated business relationship with them. This guide sets out a practical approach to requesting that evidence. It is general information, not legal or compliance advice.

Action plan

1 Explain why you're asking before you ask Clients generally respond better to an identity request when they understand why it's needed.

A short, plain explanation that identity verification is a standard part of your firm's onboarding for a matter like theirs, not a one-off suspicion, generally reduces friction and follow-up questions. Tell the client what you need and roughly how it will be used before you ask for it.

  • Explain that identity verification is a standard part of onboarding, not specific to them
  • Tell the client what will happen to the documents once received
  • Give a short, clear list of exactly what's needed

Done when: The client has been told why identity evidence is needed and what will happen to it

2 Collect the customer information standard due diligence requires New Zealand's CDD standard sets out specific information reporting entities must obtain for an individual customer.

Department of Internal Affairs guidance for AML/CFT reporting entities sets out that standard customer due diligence requires obtaining the customer's full name, date of birth, and address. Ask for evidence of each of these rather than relying on a client's verbal confirmation.

  • Ask for the client's full legal name, date of birth, and current address
  • Request documents that evidence each of these details, not just a verbal statement
  • Confirm against your firm's own AML/CFT programme what document combination it requires

Done when: The client's full name, date of birth, and address have each been evidenced with supporting documents

DIA: AML/CFT FAQ for reporting entities
3 Verify the documents, don't stop at collecting them Collecting identity documents is only half of the obligation; verification is a separate step.

DIA's guidance is explicit that once you've obtained the required customer information, you must take reasonable steps to verify it using documents, data, or information from reliable and independent sources. Treat verification as a distinct step in your intake process, not something collection alone satisfies.

  • Verify each document against a reliable and independent source, not just check it looks genuine
  • Don't treat collection alone as completing the due diligence step
  • Record which source was used to verify each piece of information

Done when: Each collected identity document has been independently verified, not only collected

See verifying identity documents against a reliable source