Regulatory Alerts2022-05-17
Customer Due Diligence - Trusts Explanatory Note
New Zealand AML/CFT supervisors clarify that trusts qualify as customers under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009, aligning domestic interpretation with Financial Action Task Force recommendations. This designation requires financial institutions to conduct customer due diligence directly on the trust entity, focusing on identifying beneficial owners who hold effective control or a vested interest exceeding 25 percent in the trust property. The guidance streamlines compliance obligations by prioritizing the verification of individuals controlling or benefiting from trust funds over the ownership structure of the trustees themselves.
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