2025-10-09
The Reserve Bank of New Zealand issued this update to clarify record-keeping obligations for trust deeds and define requirements for ongoing customer due diligence under the AML/CFT Act 2009. The regulator recommends retaining only relevant sections of trust deeds rather than full copies and mandates a risk-based approach for reviewing existing customers, prioritizing high-risk accounts and those with material changes. Additionally, the document highlights key themes from 2018 on-site visits, including concerns regarding risk assessment methodologies, key person risk, and the varying quality of Section 59 audits.