Date posted: 29/07/2019 4 min read

2019 annual AML/CFT report obligations – interim solution for corporate trustee companies

Corporate Trustee Annual Reporting Requirements 2019.

In brief

  • Exemptions are being considered where a corporate trustee company is a subsidiary of a law firm, accounting practices or TCSP that is a reporting entity in NZ
  • The DIA has implemented a temporary and interim solution while the exemption is being assessed
  • Exemptions apply only to certain corporate trustee companies that are subsidiaries

The Ministry of Justice is considering a class exemption for situations in which a corporate trustee company is a subsidiary of a law firm, accounting practice or trust and company service provider (TCSP) that is a reporting entity under the AML/CFT Act.

The Department of Internal Affairs (DIA) has implemented a temporary and interim solution for corporate trustee companies relating to their annual reporting obligations while the exemption application is being assessed.

This means that a corporate trustee company whose AML/CFT obligations are being fulfilled by a parent law firm, accounting practice or TCSP (this includes parent reporting on information relating to all relevant activities of the subsidiary corporate trustee company) that is a reporting entity in New Zealand is not required to submit an annual report by 31 August 2019.

In addition to wholly owned subsidiaries, the DIA allows for the interim solution relating to 2019 annual reports to be applied to corporate trustee companies wholly owned by one of the following:

i) an accountant in public practice, and practising in partnership, that is a partner.
ii) a solicitor in public practice, and practising in partnership, that is a partner.
iii) a solicitor in sole practice.
iv) an accountant in sole practice.

The temporary and interim solution applies to annual report obligations for the period 1 July 2018 to 30 June 2019 only.

Corporate Trustee Annual Reporting Requirements 2019

For further information visit the DIA’s website.

Find out more