Many reporting entities find it challenging to apply customer due diligence (CDD) consistently across different customer types – especially for non-standard structures like clubs, co-operatives, sole traders, and partnerships. To help with this, the Department of Internal Affairs (DIA), released updated CDD guidance on 30 September 2025.
The update clarifies what information reporting entities must collect and verify for these specific customer types, and how to apply CDD proportionately based on risk.
What’s changed
The new guidance:
- Clarifies how to identify and verify the beneficial owners or controlling persons of clubs, societies, and co-operatives.
- Explains how to apply CDD to sole traders and partnerships, including when additional verification may be needed.
- Highlights how to document your rationale when simplified or enhanced CDD is applied.
- Provides practical examples to support consistent application across entities supervised by the DIA, FMA, and RBNZ.
What you should do now
- Read the updated guidance: Updated Customer Due Diligence Guidance
- Review your AML/CFT programme, procedures, and client onboarding checklists to make sure they reflect the new expectations.
- Train your team on how to identify the right information for these customer types.
- Document any updates made to demonstrate your programme remains current.
How Strategi can help
We can review your AML/CFT documentation, client forms, and CDD procedures to ensure they align with the latest supervisor expectations. Our team also delivers tailored AML refresher training and gap assessments to help you stay compliant and audit-ready.
Next steps
If your business deals with clubs, societies, co-ops, sole traders, or partnerships, now’s the time to review your approach. Contact the Strategi Compliance team for support updating your AML/CFT programme and training