By now, you know what the Panama Papers are. You’ve read about how New Zealand has been implicated and the New Zealand government’s response to it. But as a reporting entity in New Zealand, do you know what you now need to do about it?


 Impacting TCSPs

The industry that has been most acutely impacted by the Panama Papers leak are those who provide offshore company and trust services in New Zealand. Under the AML/CFT Act, they are known as Trust and Company Service Providers (TCSPs). Their AML regulator in New Zealand, the Department of Internal Affairs (DIA), have been in touch with relevant TCSPs to remind them about their AML obligations; no doubt further changes are coming for them.


Understanding Beneficial Ownership

There are two other groups that need to pay attention to the impact of the Panama Papers. The first is any reporting entity that deal with companies and trusts as customers. The reason? You must identify and verify the beneficial owners of these customers; under the AML/CFT Act, beneficial owner in New Zealand means an individual who owns 25{37bdd4c223d4a7cf5f55956567c78ad3335a9798c1f68f1890044a4577de9da9} or more of a company or trust, or those who have effective control of that company or trust.

Reporting entities in New Zealand must “look behind” a legal entity to understand and document the individuals who are operating and moving money around behind the scenes. This can, of course, get very complicated.


Preparing Professional Gatekeepers

The other group that will be impacted heavily by the fallout from the Panama Papers are lawyers and accountants in New Zealand. These professional service providers are known as “gatekeepers” in the New Zealand AML/CFT regime. Phase 2 of the New Zealand AML/CFT Act is expected at any moment, and will extend the requirements of existing reporting entities to these new industries. Given offshore companies and trusts usually rely on the involvement of these professional services providers, the new requirements will change how these entities operate.


The Panama Papers were an unprecedented leak which is likely to impact industries and economies in unprecedented ways. It is clear that AML requirements are destined to become stricter in the near future in New Zealand, particularly for those dealing with beneficial owners and professional gatekeepers.


Are you having trouble understanding beneficial owners in your business? Contact Fiducia for a no-obligation consultation at