Anti-money laundering and countering financing of terrorism

Steindle Williams Legal 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 being acting, or continue to act, for you until we have completed customer due diligence in accordance with the requirements of the AML/CFT Act.

What is customer due diligence?

The AML/CFT Act requires Steindle Williams Legal 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 before we act for you, the information and supporting documents we require will depend on the nature of the week 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.

Our process

If Steindle Williams Legal 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, we use an electronic verification system call 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.

Handling your information

Any personal information that Steindle Williams Legal 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.

APLYiD

For clients located in New Zealand, 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.

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:

  • Steindle Williams Legal 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 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 Steindle Williams Legal’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

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 produce by APLYiD and save this in our systems. The information in the APLYiD
the 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 identity verification process.

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 https://app.aplyid.com/about/privacy-policy.

Questions

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 Legal contact person or our AML/CFT compliance team at lawyers@swlegal.co.nz