The Act Makes a Bank Collect Your Address and Then Says in Brackets That It Need Not Verify It
What a New Zealand bank must establish before it opens an account comes from the Anti-Money Laundering and Countering Financing of Terrorism Act 2009, and the Act is more specific than most. Section 14(1)(a) makes standard customer due diligence compulsory whenever a reporting entity establishes a business relationship with a new customer. Section 15 then lists the identity information that must be obtained: full name, date of birth, the person's relationship to the customer if they are not the customer, the person's address or registered office, the company identifier or registration number, and anything prescribed by rules. Section 16(1)(a) sets the verification duty, and it carries a parenthesis that does a lot of work - the reporting entity must take reasonable steps to satisfy itself that the information obtained under section 15 is correct, 'other than the information obtained under section 15(d)', which is the address. So the statute requires the bank to collect an address and does not require it to verify one. Section 16(1A) repeats the point for beneficial owners and people acting on behalf. Timing is the other half. Section 16(2) requires verification before the business relationship is established, and section 16(3) allows it to be completed afterwards only where it is essential not to interrupt normal business practice, the risks are managed by transaction limits and account monitoring, and verification is finished as soon as practicable. That is the legal basis for an account opened on arrival with limits on it. Two features of a newly arrived migrant's situation trigger the heavier regime instead. Section 22(1)(a)(ii) requires enhanced customer due diligence for a non-resident customer from a country with insufficient anti-money laundering measures, and section 22(1)(a)(i) requires it for a trust or another vehicle for holding personal assets - which catches a family trust brought from abroad. Enhanced due diligence under sections 23 and 24 adds information about the source of the funds or the wealth, and verification of it.
At a glance
- Identity information a bank must obtain
- Full name, date of birth, relationship to the customer where relevant, address or registered office, company identifier, and anything in the rules
Section 15 of the Anti-Money Laundering and Countering Financing of Terrorism Act 2009. Section 15(f) was amended on 1 July 2026 to point at rules made under section 156B.
- Information the bank need not verify
- The address, under section 15(d)
Section 16(1)(a) excludes it by name from the verification duty, and section 16(1A) repeats the exclusion for beneficial owners and persons acting on behalf.
- When verification must be done
- Before the business relationship is established
Section 16(2). Section 16(3) allows completion afterwards only where it is essential not to interrupt normal business practice, risks are managed by transaction limits and account monitoring, and verification is completed as soon as practicable.
- What triggers enhanced due diligence for an arriving migrant
- Being a non-resident customer from a country with insufficient AML measures, or bringing a trust
Section 22(1)(a)(i) and (ii). The Act does not name the countries; it describes them.
- Minimum balance or deposit required by the Act
- None in the customer due diligence subpart of the Anti-Money Laundering and Countering Financing of Terrorism Act 2009
Sections 10 to 31 were read for the due diligence requirements and none of them sets a sum. What an individual bank requires is a matter for that bank and nothing published by any bank was read.
Requirements
- Full name and date of birth
- An address or registered office, which the Act requires the bank to obtain but not to verify
- Reasonable steps by the bank to satisfy itself that the rest of the information is correct
- Verification completed before the relationship starts, unless the narrow exception in section 16(3) applies
- Enhanced due diligence, including source of funds or wealth, for a trust, a company with nominee or bearer shares, or a non-resident from a country with insufficient AML measures
In detail
The address exception, and why it matters to someone who has just arrived
Proof of address is the thing that most often stops a new arrival opening an account: there is no tenancy yet, no utility bill, no bank statement at a New Zealand address. The Act does not require any of it. Section 15(d) makes the bank obtain an address; section 16(1)(a) then exempts that one item from the verification duty in terms, and section 16(1A) says again that the verification duties for beneficial owners and agents do not require steps to verify information obtained under section 15(d). A bank is free to demand proof of address anyway as a matter of its own policy, and many do, but it is not doing so because the statute requires it. What the statute requires to be verified is name and date of birth.
Opening an account before you arrive, and the exception that allows it
Section 16(2) states the default: verification before the relationship starts. The exception in section 16(3) is the legal basis for the practice of opening an account from overseas and completing identification on arrival, and it is conditional rather than general - it needs all three of its limbs, including that the money laundering risk is managed by transaction limitations and account monitoring in the meantime. That is why an account opened this way is typically restricted until the customer presents identity documents in person.
What pushes a migrant into the heavier regime
Two of the enhanced due diligence triggers in section 22(1)(a) are ordinary features of moving country. The first is being a non-resident customer from a country the bank judges to have insufficient anti-money laundering measures - a judgement about the country of origin rather than about the person. The second is a trust or another vehicle for holding personal assets, which catches anyone who has structured their savings that way before moving. Enhanced due diligence under sections 23 and 24 requires information about the source of the funds or the wealth, and verification of it according to the level of risk.
Exceptions by origin
No exceptions recorded
Nothing we have read treats any nationality differently for this topic. The rule above applies to everyone.
What the law says
«if the reporting entity establishes a business relationship with a new customer:»Known to be out of date. The page carries the publisher's own line 'Some amendments have not yet been incorporated'.
The other circumstances are an occasional transaction, a material change in an existing relationship where the entity has insufficient information, and anything added by rules.
Read it at the sourceAbout this source
The Parliamentary Counsel Office publishes New Zealand's Acts and secondary legislation here, and the Legislation Act 2019 gives what it publishes a legal status most publishers in this corpus do not have. Section 78(1) lets the PCO publish official electronic versions; section 79(1)(b) says that an official version that is a consolidation 'is taken to correctly state, as at its stated date, the law enacted or made by the legislation consolidated and by the amendments', and section 79(3) adds that the presumptions apply 'unless the contrary is shown'. Each Act carries its own 'as at' date on the page: the Immigration Act 2009 read on 11 October 2026 is as at 10 July 2026. A `whole.html` address returns the entire instrument in one document, which is what makes an exhaustive negative claim possible here.
Standing: Maintains the text in force
Cannot be cited for: The 'as at' date is a cut-off and the page states it without calling it one, so every citation of a consolidated text needs `consolidatedAsOf`. Worse, some pages carry the line 'Some amendments have not yet been incorporated' - the Immigration (Visa, Entry Permission, and Related Matters) Regulations 2010 did on 11 October 2026 - and that is a consolidation gap stated by the publisher itself. Section 79A says the PCO's own publication notes, legislative history and machine-readable links do not form part of the official text, so the amendment notes under each section are not law. It cannot be cited for immigration instructions: those are not legislation and are not published here at all.
We re-read it every 90 days. More about this source
«A reporting entity must obtain the following identity information in relation to the persons referred to in section 11(1):»Known to be out of date. The page carries the publisher's own line 'Some amendments have not yet been incorporated'.
Six paragraphs follow, lettered (a) to (f). Paragraph (d) is the address or registered office.
Read it at the sourceAbout this source
The Parliamentary Counsel Office publishes New Zealand's Acts and secondary legislation here, and the Legislation Act 2019 gives what it publishes a legal status most publishers in this corpus do not have. Section 78(1) lets the PCO publish official electronic versions; section 79(1)(b) says that an official version that is a consolidation 'is taken to correctly state, as at its stated date, the law enacted or made by the legislation consolidated and by the amendments', and section 79(3) adds that the presumptions apply 'unless the contrary is shown'. Each Act carries its own 'as at' date on the page: the Immigration Act 2009 read on 11 October 2026 is as at 10 July 2026. A `whole.html` address returns the entire instrument in one document, which is what makes an exhaustive negative claim possible here.
Standing: Maintains the text in force
Cannot be cited for: The 'as at' date is a cut-off and the page states it without calling it one, so every citation of a consolidated text needs `consolidatedAsOf`. Worse, some pages carry the line 'Some amendments have not yet been incorporated' - the Immigration (Visa, Entry Permission, and Related Matters) Regulations 2010 did on 11 October 2026 - and that is a consolidation gap stated by the publisher itself. Section 79A says the PCO's own publication notes, legislative history and machine-readable links do not form part of the official text, so the amendment notes under each section are not law. It cannot be cited for immigration instructions: those are not legislation and are not published here at all.
We re-read it every 90 days. More about this source
«take reasonable steps to satisfy itself that the information obtained under section 15(other than the information obtained under section 15(d)) is correct; and»Known to be out of date. The page carries the publisher's own line 'Some amendments have not yet been incorporated'.
The missing space before the bracket is the publisher's, caused by the end of a hyperlink to section 15. The carve-out for section 15(d) means the Act does not require an address to be proved.
Read it at the sourceAbout this source
The Parliamentary Counsel Office publishes New Zealand's Acts and secondary legislation here, and the Legislation Act 2019 gives what it publishes a legal status most publishers in this corpus do not have. Section 78(1) lets the PCO publish official electronic versions; section 79(1)(b) says that an official version that is a consolidation 'is taken to correctly state, as at its stated date, the law enacted or made by the legislation consolidated and by the amendments', and section 79(3) adds that the presumptions apply 'unless the contrary is shown'. Each Act carries its own 'as at' date on the page: the Immigration Act 2009 read on 11 October 2026 is as at 10 July 2026. A `whole.html` address returns the entire instrument in one document, which is what makes an exhaustive negative claim possible here.
Standing: Maintains the text in force
Cannot be cited for: The 'as at' date is a cut-off and the page states it without calling it one, so every citation of a consolidated text needs `consolidatedAsOf`. Worse, some pages carry the line 'Some amendments have not yet been incorporated' - the Immigration (Visa, Entry Permission, and Related Matters) Regulations 2010 did on 11 October 2026 - and that is a consolidation gap stated by the publisher itself. Section 79A says the PCO's own publication notes, legislative history and machine-readable links do not form part of the official text, so the amendment notes under each section are not law. It cannot be cited for immigration instructions: those are not legislation and are not published here at all.
We re-read it every 90 days. More about this source
«Except as provided in subsection (3), a reporting entity must carry out verification of identity before establishing a business relationship or conducting an occasional transaction or activity.»Known to be out of date. The page carries the publisher's own line 'Some amendments have not yet been incorporated'.
About this source
The Parliamentary Counsel Office publishes New Zealand's Acts and secondary legislation here, and the Legislation Act 2019 gives what it publishes a legal status most publishers in this corpus do not have. Section 78(1) lets the PCO publish official electronic versions; section 79(1)(b) says that an official version that is a consolidation 'is taken to correctly state, as at its stated date, the law enacted or made by the legislation consolidated and by the amendments', and section 79(3) adds that the presumptions apply 'unless the contrary is shown'. Each Act carries its own 'as at' date on the page: the Immigration Act 2009 read on 11 October 2026 is as at 10 July 2026. A `whole.html` address returns the entire instrument in one document, which is what makes an exhaustive negative claim possible here.
Standing: Maintains the text in force
Cannot be cited for: The 'as at' date is a cut-off and the page states it without calling it one, so every citation of a consolidated text needs `consolidatedAsOf`. Worse, some pages carry the line 'Some amendments have not yet been incorporated' - the Immigration (Visa, Entry Permission, and Related Matters) Regulations 2010 did on 11 October 2026 - and that is a consolidation gap stated by the publisher itself. Section 79A says the PCO's own publication notes, legislative history and machine-readable links do not form part of the official text, so the amendment notes under each section are not law. It cannot be cited for immigration instructions: those are not legislation and are not published here at all.
We re-read it every 90 days. More about this source
«Verification of identity may be completed after the business relationship has been established if—»Known to be out of date. The page carries the publisher's own line 'Some amendments have not yet been incorporated'.
All three conditions must hold: it is essential not to interrupt normal business practice, the risks are managed by transaction limitations and account monitoring, and verification is completed as soon as practicable.
Read it at the sourceAbout this source
The Parliamentary Counsel Office publishes New Zealand's Acts and secondary legislation here, and the Legislation Act 2019 gives what it publishes a legal status most publishers in this corpus do not have. Section 78(1) lets the PCO publish official electronic versions; section 79(1)(b) says that an official version that is a consolidation 'is taken to correctly state, as at its stated date, the law enacted or made by the legislation consolidated and by the amendments', and section 79(3) adds that the presumptions apply 'unless the contrary is shown'. Each Act carries its own 'as at' date on the page: the Immigration Act 2009 read on 11 October 2026 is as at 10 July 2026. A `whole.html` address returns the entire instrument in one document, which is what makes an exhaustive negative claim possible here.
Standing: Maintains the text in force
Cannot be cited for: The 'as at' date is a cut-off and the page states it without calling it one, so every citation of a consolidated text needs `consolidatedAsOf`. Worse, some pages carry the line 'Some amendments have not yet been incorporated' - the Immigration (Visa, Entry Permission, and Related Matters) Regulations 2010 did on 11 October 2026 - and that is a consolidation gap stated by the publisher itself. Section 79A says the PCO's own publication notes, legislative history and machine-readable links do not form part of the official text, so the amendment notes under each section are not law. It cannot be cited for immigration instructions: those are not legislation and are not published here at all.
We re-read it every 90 days. More about this source
«a non-resident customer from a country that has insufficient anti-money laundering and countering financing of terrorism systems or measures in place:»Known to be out of date. The page carries the publisher's own line 'Some amendments have not yet been incorporated'.
The Act names no country. Which countries a bank treats this way is a judgement for the bank, informed by material from its AML/CFT supervisor that was not read.
Read it at the sourceAbout this source
The Parliamentary Counsel Office publishes New Zealand's Acts and secondary legislation here, and the Legislation Act 2019 gives what it publishes a legal status most publishers in this corpus do not have. Section 78(1) lets the PCO publish official electronic versions; section 79(1)(b) says that an official version that is a consolidation 'is taken to correctly state, as at its stated date, the law enacted or made by the legislation consolidated and by the amendments', and section 79(3) adds that the presumptions apply 'unless the contrary is shown'. Each Act carries its own 'as at' date on the page: the Immigration Act 2009 read on 11 October 2026 is as at 10 July 2026. A `whole.html` address returns the entire instrument in one document, which is what makes an exhaustive negative claim possible here.
Standing: Maintains the text in force
Cannot be cited for: The 'as at' date is a cut-off and the page states it without calling it one, so every citation of a consolidated text needs `consolidatedAsOf`. Worse, some pages carry the line 'Some amendments have not yet been incorporated' - the Immigration (Visa, Entry Permission, and Related Matters) Regulations 2010 did on 11 October 2026 - and that is a consolidation gap stated by the publisher itself. Section 79A says the PCO's own publication notes, legislative history and machine-readable links do not form part of the official text, so the amendment notes under each section are not law. It cannot be cited for immigration instructions: those are not legislation and are not published here at all.
We re-read it every 90 days. More about this source
«a trust or another vehicle for holding personal assets:»Known to be out of date. The page carries the publisher's own line 'Some amendments have not yet been incorporated'.
About this source
The Parliamentary Counsel Office publishes New Zealand's Acts and secondary legislation here, and the Legislation Act 2019 gives what it publishes a legal status most publishers in this corpus do not have. Section 78(1) lets the PCO publish official electronic versions; section 79(1)(b) says that an official version that is a consolidation 'is taken to correctly state, as at its stated date, the law enacted or made by the legislation consolidated and by the amendments', and section 79(3) adds that the presumptions apply 'unless the contrary is shown'. Each Act carries its own 'as at' date on the page: the Immigration Act 2009 read on 11 October 2026 is as at 10 July 2026. A `whole.html` address returns the entire instrument in one document, which is what makes an exhaustive negative claim possible here.
Standing: Maintains the text in force
Cannot be cited for: The 'as at' date is a cut-off and the page states it without calling it one, so every citation of a consolidated text needs `consolidatedAsOf`. Worse, some pages carry the line 'Some amendments have not yet been incorporated' - the Immigration (Visa, Entry Permission, and Related Matters) Regulations 2010 did on 11 October 2026 - and that is a consolidation gap stated by the publisher itself. Section 79A says the PCO's own publication notes, legislative history and machine-readable links do not form part of the official text, so the amendment notes under each section are not law. It cannot be cited for immigration instructions: those are not legislation and are not published here at all.
We re-read it every 90 days. More about this source
Practical notes
Sections 23 and 24, which set out what enhanced customer due diligence actually requires, were seen in the Act's contents and in the cross-references quoted here but were not read in full.
The Identity Verification Code of Practice issued by New Zealand's AML/CFT supervisors was not read. It is where the practical documentary standard lives, and nothing in this record states what documents a bank will accept.
Nothing published by any New Zealand bank was read. A bank's own account-opening conditions are primary evidence about that bank only, and no figure for a minimum deposit, a fee or a waiting period appears here because none was read in an instrument.
The Act was read in the version the publisher dates 1 July 2026, and the page carries the line 'Some amendments have not yet been incorporated'. Two amendment Acts of 2026 - 2026 No 16 and 2026 No 17 - already appear in the amendment notes on the provisions quoted here, so this part of the Act is moving.
Tax matters attached to opening an account - an IRD number, resident withholding tax rates, the common reporting standard - were not read.
- consolidatesAnti-Money Laundering and Countering Financing of Terrorism Act 2009, version as at 1 July 2026
New Zealand Legislation, Parliamentary Counsel Office · consolidated to 2026-07-01
Known to be out of date. The page carries the line 'Some amendments have not yet been incorporated'.
About this source
The Parliamentary Counsel Office publishes New Zealand's Acts and secondary legislation here, and the Legislation Act 2019 gives what it publishes a legal status most publishers in this corpus do not have. Section 78(1) lets the PCO publish official electronic versions; section 79(1)(b) says that an official version that is a consolidation 'is taken to correctly state, as at its stated date, the law enacted or made by the legislation consolidated and by the amendments', and section 79(3) adds that the presumptions apply 'unless the contrary is shown'. Each Act carries its own 'as at' date on the page: the Immigration Act 2009 read on 11 October 2026 is as at 10 July 2026. A `whole.html` address returns the entire instrument in one document, which is what makes an exhaustive negative claim possible here.
Standing: Maintains the text in force
Cannot be cited for: The 'as at' date is a cut-off and the page states it without calling it one, so every citation of a consolidated text needs `consolidatedAsOf`. Worse, some pages carry the line 'Some amendments have not yet been incorporated' - the Immigration (Visa, Entry Permission, and Related Matters) Regulations 2010 did on 11 October 2026 - and that is a consolidation gap stated by the publisher itself. Section 79A says the PCO's own publication notes, legislative history and machine-readable links do not form part of the official text, so the amendment notes under each section are not law. It cannot be cited for immigration instructions: those are not legislation and are not published here at all.
We re-read it every 90 days. More about this source