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 customer due diligence in accordance with the requirements of the AML/CFT Act.
The AML/CFT Act requires Buddle Findlay to conduct customer due diligence on a client, any beneficial owner of a client or any person acting on behalf of a client before we commence acting for that client where the client has requested that we act in relation to certain captured activities (as defined in the AML/CFT Act).
If we need to complete customer due diligence before we act for you, the information and supporting documents we require will depend on the nature of the work we have been asked to carry out. We may need to obtain information about you personally, a company or trust that you are connected to and/or other relevant persons (such as directors and shareholders of a company, or trustees and beneficiaries of a trust). That information includes, for each relevant person, the person’s:
- 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 customer due diligence before we act for you, 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.
If Buddle Findlay needs to conduct customer due diligence before we act for you, your contact person will discuss the steps and explain exactly what information is required.
For clients in New Zealand and Australia, we use an electronic verification system called APLYiD to collect the necessary due diligence information and supporting evidence (www.aplyid.com). For more information about this process, and the information collected by APLYiD, please see the section entitled 'APLYiD' below.
Alternatively, we can verify your information in person or via a trusted referee. For more information on the documentation that we accept, please discuss this with your Buddle Findlay contact person.
Any personal information that Buddle Findlay collects as part of the customer 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.
For clients located in New Zealand and Australia, we use an electronic verification system called APLYiD to collect the necessary information and supporting information about relevant persons in your business (www.aplyid.com). APLYiD 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.
How to use APLYiD
To use APLYiD, you will need a smart phone and a driver licence or passport.
The process of verifying your personal information is as follows:
- Buddle Findlay will send you a text message, which includes a link to start the APLYiD process. The process does not require you to download any apps onto your phone. You simply click on the link contained in the text message
- You will be prompted to take photos on your smart phone of your New Zealand or Australian driver licence or passport
- APLYiD extracts information from the photos you have taken and gives you the opportunity to correct any errors
- You will be prompted to enter your current residential address
- You will be prompted to take a short video of yourself (front and side of your face), which the APLYiD system matches against the photo on your driver licence or passport
- APLYiD will check the information you have provided against various sources, including:
- databases of government and financial institutions in New Zealand and Australia
- international databases of Politically Exposed Persons (as that term is defined in the AML/CFT Act) and sanctions - APLYiD will produce a report for Buddle Findlay's AML/CFT compliance team to review and download.
Please note that we may have to request further information from you in certain circumstances.
Collecting, handling and deleting your personal information
Buddle Findlay’s uses APLYiD to verify and identify individuals.
Once you have completed the APLYiD process, our AML/CFT compliance team will download a report produced by APLYiD and save this in our systems. The information in the APLYiD report may include the following personal information:
- Information from your driver licence or passport, including your photo
- Your residential address and phone number
- A screenshot (photo) from the short video you have taken
- A summary of databases which APLYiD searched
- Whether you passed or failed APLYiD's identify verification process.
Buddle Findlay holds any personal information in accordance with our Privacy Policy.
Once our AML/CFT compliance team has downloaded an APLYiD report, APLYiD will delete all personal information it has collected from you and then archive the record within five minutes of the download. The archived data in APLYiD includes a reference number, but no personal information. Even if no report is downloaded, APLYiD will automatically delete any personal information seven days after you have completed the APLYiD process.
APLYiD’s system is hosted on Amazon Web Services in Sydney, Australia. APLYiD’s privacy policy can be found here.
If you have any questions about the customer due diligence 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.