From an ML/FT risk perspective charities (particularly overseas charities) are considered high risk. However, certain attributes can reduce risk, specifically:
if the charity is registered in New Zealand; and
if the charity is well known and its charitable purpose is clear.
Where a charity is a client/beneficial owner and therefore is subject to CDD requirements, the following steps will need to be taken:
Search the charity on the following website to confirm that they are a registered NZ charity https://register.charities.govt.nz/CharitiesRegister/Search
You will need to retain the evidence of registration on your client files.
Identification of the officers of the charity, whose details are listed on the charities website.
In order identify the officers you will need to identify the name, date of birth and address of each of the individuals, as per the Code of Practice/your Compliance Programme. You will not always need to identify all officers, as some may not be deemed to necessarily have effective controls. Your decisions in regards to effective control will need to be documented on the client file.
Where a Charity is a trust structure, you will need to perform Enhanced CDD on them. However, this is often very simple as registered entities are required to upload their annual returns on the Charities’ website.