AML - Customer Due Diligence (CDD)


Using the AML - Customer Due Diligence tool

  • This tool is meant to complement your current AML programme by creating a paper trail to show AML CDD if required when forming a company, authorising funds for payroll and doing a share transfer.

Method of identification

  • There are three options to choose from:

    • Sight their ID in person and verify true likeness then take a copy for records​

    • Obtain a certified copy of their ID

    • Use Electronic IDV such as 2Shakes

  • If the Certified Copy option is chosen, you can choose to generate some correspondence to send to your client explaining what is required (who they can get to certify the copies).

  • Letter from government agency - you may already have something on file or access to an IRD letter for your client.  If not, ask them to supply this.

  • The workpaper will give you the option of uploading copies of the ID, or just stating where they are saved (to minimize double-handling).

Enhanced Customer Due Diligence

  • In most cases, you will need to conduct standard customer due diligence (collecting and verifying their ID as per the AML - Customer Due Diligence workpaper), however in certain circumstances you will also need to verify their source of wealth and source of funds. This is called Enhanced Customer Due Diligence.


Other Entity Information

  • If you're forming a company for someone, the natural person(s) who have 25% or more ownership, have effective control or are an agent acting on behalf, is your customer and that is who you will be conducting the CDD on. You would not have a company number or NZBN at this stage as the company has not been formed yet. However, once the company has been formed, you could come back to this workpaper and record it  - otherwise you could N/A this step.




Customer Due Diligence


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