Progress on Beneficial Ownership: A Step Forward, But a Long Road Remains

The Government’s renewed commitment to establishing a beneficial ownership register marks an important, if overdue, step in strengthening New Zealand’s defences against corruption, organised crime, and financial misconduct.

On 20 December 2025, Associate Police Minister Casey Costello unveiled an all-of-government plan to combat organised crime, including a commitment to “implement a beneficial ownership register for companies and limited partnerships.” The initiative forms part of the Government’s Transnational Serious Organised Crime (TSOC) strategy and will be overseen by the Ministry of Business, Innovation and Employment (MBIE).  

According to the Government, success will be measured by a “reduction in the misuse of companies and limited partnerships for illicit purposes, including money laundering, bribery and corruption, insider dealings, tax evasion, and terrorism financing,” and by improved ability for authorities to “follow the money” and confiscate criminal assets.

Costello told interest.co.nz that the register would help “prevent organised criminal groups from being able to disguise business structures and hide assets.” Transparency International New Zealand (TINZ) strongly agrees with this assessment. Anonymous company ownership has long been recognised as a key enabler of corruption and financial crime, both domestically and internationally.

Commerce and Consumer Affairs Minister Scott Simpson confirmed that work on the register will proceed within the TSOC strategy’s five-year timeframe, noting that “significant work has already been completed” and that New Zealand’s approach has been informed by international experience, including in the United Kingdom and Singapore. He also emphasised that the register will be “tailored to New Zealand’s context.”  

The timeframe in the Action Plan places the BO Register as a Priority 2 action, so actual implementation may be delayed further, out to 2027 or beyond.

The renewed commitment to get back on track is welcome. The prospect of future greylisting from the Financial Action Task Force (FATF) is likely to provide a strong incentive to act with greater urgency. As a powerful global watchdog, FATF now requires jurisdictions to ensure that beneficial ownership information is readily available, reinforcing transparency as a core anti-corruption standard. It was critical of New Zealand’s performance in this area in its 2021 evaluation.

New Zealand government agencies, supported by advice from across departments, have acknowledged that tools such as a beneficial ownership register are essential if the country is to keep pace with its international peers in countering organised crime and corruption. Officials have warned that New Zealand cannot afford to fall behind global standards.

Successive governments have recognised the risks posed by opaque ownership structures. Yet despite these repeated acknowledgements, progress toward concrete implementation has remained slow.

Two advocacy areas for TINZ will be the extent of openness of any register and whether the government intends to address the threat of trusts.  On more public accessibility (ie not just accessible by regulatory agencies,, there is plenty of evidence from the work of the Organised Crime and Corruption Reporting Project , the International Consortium of Investigative Journalists and Transparency International Chapters of how useful open beneficial ownership registers are at lifting the veil of opacity by enabling the media, academics and civil society to connect dots.

On the matter of inclusion of trusts, Associate Justice Minister Nicole McKee acknowledged that a trusts register “could provide benefits for law enforcement agencies” by helping identify assets and “the natural persons behind them.” However, she cited concerns about costs, compliance burdens, and data security, and confirmed that “no final decisions have been made.”

While trusts are a legitimate and widely used tool for managing personal and commercial finances, they are also attractive to money launderers and financiers of terrorism. Proceeds of crime can be deposited into trust bank accounts, used to purchase assets or property, and moved through multiple transactions as part of “layering” schemes designed to conceal their origin. Trusts can also be used to shift assets between different legal entities, making detection more difficult through complex ownership structures.

What makes trusts particularly vulnerable to abuse is their lack of transparency. They are generally not public or subject to meaningful disclosure requirements, allowing those who ultimately control them to remain hidden. This secrecy enables individuals to obscure their involvement behind legal arrangements that are difficult for authorities to penetrate.

A recent investigation in the United Kingdom highlighted how trusts are increasingly emerging as a weak point in compliance and reporting systems, reinforcing concerns about their role in facilitating financial crime.

Significant risks associated with trusts in New Zealand have been identified in threat assessments by the Financial Intelligence Unit (FIU) and other agencies). These agencies have highlighted high levels of vulnerability, noting that trusts are often hidden behind companies with no public record of ownership, providing effective concealment for criminal activity.

On average, “trust” is the fourth most frequently referenced keyword in Suspicious Transaction Reports (STRs), underscoring its relevance in financial crime investigations.

TINZ recognises that establishing a trusts’ register raises legitimate operational, legal, and privacy concerns, all of which deserve careful consideration. However, excluding them from transparency reforms risks leaving a major gap in New Zealand’s anti-corruption framework.

TINZ welcomes the Government’s renewed engagement with beneficial ownership transparency. However, meaningful impact will depend on timely implementation, strong verification mechanisms, and public access that enables scrutiny.

The article from invest.co.nz “Government rejoins the long and winding road towards a beneficial ownership register for companies and limited partnerships. But what about trusts?” is well researched and informative.

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