1. Knowledge
  2. Tax Pooling 101

AML requirements

What are your processes for anti-money laundering (AML)?

What are your AML requirements?  

Tax pools have a partial exemption from the requirements of the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (Act).  Our limited AML requirements are as follows: 

  • in respect of each client that is a company, we must hold identity information that is publicly  available in relation to that company; 
  • in respect of all clients, we must hold identity information (name and date of birth) for at least one individual who has authority to act on behalf of the client; 
  • before a taxpayer’s tax pooling funds are transferred to Inland Revenue, we must confirm the amount is to meet the taxpayer’s expected or actual tax liability that the transfer is made to satisfy; and 
  • when a taxpayer requests a refund, we must ensure the taxpayer has completed customer due diligence to the level required under the Act. 

What are your processes for anti-money laundering (AML)? 

Our processes for AML are intended to be as streamlined as possible with tax pooling transactions: 

  • we request identity information upon customer registration/sign-up (or for existing customers, a date-of-birth pop-up will appear the next time they log in on our online portal, which will be a one-off prompt); 
  • for amounts transferred to Inland Revenue, customers will need to confirm (via a checkbox) that the amounts requested to be transferred to Inland Revenue are to meet an expected or actual tax liability of the taxpayer; and 
  • when a customer requests a refund in excess of $1,000, we will request identity information from the customer, which will need to be verified online via Cloudcheck. 

What is the online process for AML? Is this complicated? Is the service secure? 

We use primarily the Cloudcheck Verifi service to complete AML verifications for people. This is a secure online service which is straightforward and easy to complete using a smartphone, tablet or computer with camera function. We will identify individuals requiring verification and will provide a link for each individual to complete their assessment. 

The whole process takes a couple of minutes to complete. The client will initially be taken to a page where they take the equivalent of a passport photo of the front and side of their face, they then will also submit a photo of their ID. Following this, on the second step of the process, the client will enter in their personal details - name, address, date of birth and the particulars of their ID. 

Following submission a report is sent to us to review. If the client successfully passes their verification, no further personal identification information is required.  If the client receives a partial pass or fail (on part or all of the assessment) we will review this and be in touch to let you know if we need anything further in support from the client. 


Note: Cloudcheck links are time limited to seven days so if we issue links to you please ensure these are passed through to your client as quickly as possible, however where the client is unable to complete the links within the required timeframe you can come back to us to have these reset upon expiry. 

My links have expired and no longer work? How can I get reset? 

Please email team@taxtraders.co.nz to obtain new links if your old links have since expired. 

Can a client still complete manual AML forms? 

Yes they can if they do not have access to a smartphone, tablet or suitable computer to be able to complete their assessment. However, this means the manual forms need to be completed along with having all necessary supporting documents verified by a trusted person (as detailed on our forms). We generally find the manual forms take longer for clients to complete and require more involvement from them due to documents having to be verified by an appropriate individual, scanned and sent to us. The online service takes away this requirement in most cases and it becomes a much faster and easier process for the client overall. 


Evidence of another tax liability has been requested before my transfer to a future income period / sell through to Inland Revenue can proceed. What do you require this for and what is acceptable? 

Due to changes to AML requirements across the tax pooling industry, excess funds can no longer be transferred to Inland Revenue (where a tax liability does not exist) with the intent of receiving a refund directly from Inland Revenue. When funds are requested to go to a future income/tax year, or are sold with the instruction to transfer to Inland Revenue, to meet our AML obligations we will request evidence of an expected or actual tax liability to support the requested transaction.