Anti-Money Laundering and Countering Financing of Terrorism
Buddle Findlay is required to comply with the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT Act). As a result, we may not be able to begin acting, or continue to act, for you until we have completed client due diligence in accordance with the AML/CFT Act.
What is client due diligence?
Client due diligence is required on a client, any beneficial owner of a client or any person acting on behalf of a client before we provide certain regulated legal services for that client.
This means we may need to obtain information about you personally, a company or trust that you are connected to and other related persons (such as directors and shareholders of a company, or trustees and beneficiaries of a trust). This includes:
- Full name
- Date of birth
- Residential address.
We are also required to obtain supporting evidence of this information.
Please note that we may be required to carry out client due diligence even though we have been acting for you for many years as the nature of the work we customarily carried out for you may have changed and we are required to ensure our records are kept up to date.
If we cannot obtain the required information from you, it is likely we will not be able to act for you.
Our process
If Buddle Findlay needs to conduct client due diligence, you will be notified by your contact person.
We use First AML, a cloud based AML/CFT and identity verification service, to collect and securely store the required information.
For New Zealand and Australian residents, we use electronic identity verification. First AML uses biometrics, OCR (optical character recognition) and trusted data sources to confirm a person’s identity, the legitimacy of a person's identification and their residential address.
Alternatively, verification can be completed in person or through a trusted referee. If required, please let your Buddle Findlay contact know and refer to our guide for acceptable forms of identification and address verification.
For any additional documents required, you will receive email requests from your Buddle Findlay contact person, or through First AML.
We will use all reasonable endeavours to make this process as quick and straightforward as possible.
Electronic verification
To complete electronic verification via First AML, you will need a smartphone and a valid New Zealand or Australian driver licence or passport.
Once you have provided your mobile number we will send a secure link via SMS message to complete verification, you will need to:
- Click on the secure link (no app download is required)
- Confirm you consent to the process
- Take a photo of your ID
- Record a short video of yourself for biometric matching to your ID
- Check the data extracted from your ID and correct any errors
- Enter your current residential address and submit.
Your data is checked against various sources including government, financial, and international databases to confirm your full name, date of birth, and residential address.
Please be aware we may need to request additional information from you in certain circumstances where information is not able to be electronically verified.
Handling your information
Any personal information that Buddle Findlay collects as part of the client due diligence process will be used exclusively for the purpose of ensuring that we meet our obligations under the AML/CFT Act and will be held in accordance with our Privacy Policy.
First AML is ISO27001 certified, and further details on its security and privacy policies can be found here.
Questions
If you have any questions about this process or the information you might be required to provide to us, please get in touch with your Buddle Findlay contact person or our AML/CFT compliance team at AMLCFT@buddlefindlay.com.