Steindle Williams Legal Limited 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 act, 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 us to conduct customer due diligence on a client, any beneficial owner of a client of 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, 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).
In terms of establishing proof of identity and/or address, that information includes, for each relevant person, the person’s:
We are also required to obtain supporting evidence of this information. On some occasions we will also require information relating to source of funds and source of wealth. The person acting or our support staff will make any additional requirements known to you.
Please note that we may be required to carry out customer due diligence before we act for you or continue to act for you where further information is required. This applies even where we have been acting for you for many years as the nature of the work we customarily carried out for you may have changed or the information obtained from you requires updating.
If we need to conduct customer due diligence before we act for you or continue to 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 contact person.
Any personal information that we collect 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 any privacy provisions contained in our terms of engagement.
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 source to confirm a person’s identity, the legitimacy
of a person’s identification and their residential address.
To use APLYiD, you will need a smart phone and a current drivers licence or passport.
The process of verifying your personal information is as follows:
Please note that we may have to request further information from you in certain circumstances.
Steindle Williams Legal 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 report may include the following personal information:
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.
We will hold any personal information in accordance with any privacy provisions contained in our terms of engagement
APLYiD’s system is hosted on Amazon Web Services. APLYiD’s privacy policy can be found here https://www.aplyid.com/nz/privacy-policy.
If you have any questions about the customer due diligence process of the information you might be required to provide us, please get in touch with your Steindle Williams contact person or our AML/CFT compliance team at megan@swlegal.co.nz