FSP Compliance Solutions for New Zealand Custodians | FSP Registration Application Support | Post-registration Risk and Compliance Management

We offer targeted support for New Zealand Custodial FSP registration and FSP registered custodians’ obligations, tailored to the nature and scale of your financial services. Our solutions are designed to help you meet the New Zealand custodial regulations under the Financial Service Providers (Registration and Dispute Resolution) Act 2008, including registration requirements, eligibility checks, and post-registration compliance expectations under relevant laws such as New Zealand's AML/CFT Act and the Fair Trading Act. We tailor our support based on:

• Your business model and target clients
• The financial services being offered
• Your operational footprint and countries of operation
• Your governance structure and available resources
• Your exposure to AML/CFT or other regulatory oversight
• Any intention to offer services to retail clients or apply for an FMA licence in the future

 

We have designed our New Zealand custodial FSP registration and compliance solutions to help you meet the baseline regulatory requirements for operating as a financial service provider in New Zealand. Our services support compliance with the New Zealand custodial FSP regime and address compliance expectations that may arise from operating under the AML/CFT framework, fair dealing provisions, or other relevant laws.

We approach New Zealand cusodial regulation and related FSP registered custodians’ obligations in a commercially oriented and goal-focused manner, providing effective support for all stages of the New Zealand custodial FSP registration process, including but not limited to the following aspects:

• FSP Registration Guidance: Advising on eligibility, registration steps, Companies Office and FSPR requirements, and how your services fit within the New Zealand custodial FSP regime.
• Pre-registration Assessment: Reviewing your structure, service offering, and client base to assess registration eligibility and related compliance risks.
• Initial Compliance Setup: Covering:

• AML/CFT advice
• AML/CFT compliance management solutions
• New Zealand Financial Licensing solutions
• Ongoing compliance advice
• Comprehensive second-line risk and compliance support, including leading the implementation of your risk management framework (RMF), compliance management framework (CMF), compliance monitoring program (CMP), compliance calendar and checklist, ongoing risk assessments, internal and external reporting, outsourced providers' management, and more
• Compliance assurance solutions, including compliance assurance program (CAP) development, implementation, and internal control testing

 

Service Coverage

This page focuses on the  New Zealand Custodial FSPR Regime Compliance. Businesses offering certain financial services in New Zealand must register on the Financial Service Providers Register (FSPR) in accordance with the Financial Service Providers (Registration and Dispute Resolution) Act 2008. This is a legal requirement for entities providing financial services, regardless of whether they also require a licence from the Financial Markets Authority (FMA) or the New Zealand Reserve Bank.

 We offer comprehensive support for a wide range of New Zealand custodial FSP applications, tailored to meet the specific needs of the following financial service providers:

• Registered-only financial service providers, including wholesale-only businesses and entities exempt from FMA licensing
• AML/CFT reporting entities supervised by the FMA, DIA, or RBNZ (Although it is not formally part of the New Zealand FSPR Regime, most New Zealand financial service providers are also considered AML/CFT reporting entities under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009).
• FMA-licensed entities, where New Zealand custodial FSP registration is a prerequisite

In addition to New Zealand custodial FSP registration services, we provide a range of ongoing risk and compliance solutions for financial institutions operating in New Zealand under various supervisory frameworks.

Beyond New Zealand custodial FSP registration, we offer a range of New Zealand custodial regulation solutions for New Zealand financial service providers offering services to wholesale customers, including FMA licensing and a range of AML/CFT solutions for New Zealand reporting entities. You can find more information about our solutions for a New Zealand custodian’s FSP registration below:

 

 

New Zealand Custodial FSP Registration Preparation

We offer a focused set of pre-registration solutions to support your entry into the New Zealand financial services environment. Our services assist with the preparation, documentation, and decision-making required for New Zealand custodial FSP registration, while also helping you understand how your operations will be treated under the FSPR Act, AML/CFT Act, and related FSP registered custodians’ obligations.

Our New Zealand custodial FSP registration preparation support includes:

• Custodial FSP Regime Guidance: Advice on whether your business needs to register, and under what financial services categories
• Compliance Readiness Review: Reviewing your service model and client base to determine eligibility for registration and identify any additional supervisory or reporting requirements
• Compliance Documentation: Assisting with the preparation of core materials needed for AML/CFT compliance or to support future licensing (e.g. policies, procedures, business plans)
• FSP Application Pack Review: Compiling and reviewing the information required to complete your New Zealand custodial FSP registration

 

 

 

 

 

 

 

New Zealand Custodial FSP Application Management 

Our New Zealand custodial FSP registration support includes:

• Document Compilation and Review: We assist in collecting and reviewing the information required for the Companies Office application, including corporate structure, controllers, and financial services offered
• Service Classification Review: We help you determine which financial services you are offering (e.g. broking, lending, DPT services, custody, etc.) and how these must be classified under the New Zealand Custodial FSP regime
• Dispute Resolution Scheme (DRS) Compliance: If your services are offered to retail clients, we advise on joining an approved DRS and documenting this appropriately in your application
• AML/CFT Supervisor Selection: We guide you in determining which AML/CFT supervisor applies to your business -FMA, DIA, or RBNZ - and assist with any associated registration requirements
• Regulator Liaison and Submission Oversight: If needed, we can act as your representative in liaising with the Companies Office or the relevant AML/CFT supervisor during or after submission
• Timeline Monitoring and Risk Review: We track submission status and highlight any compliance red flags that may require remediation after registration (e.g. suitability of directors, operational readiness)

 

 

 

 

 

 

 

Post-Registration and New Zealand Custodial Regulation Support

Registration on the Financial Service Providers Register (FSPR) is not the end of your compliance journey. Registered FSPs remain subject to ongoing compliance expectations under New Zealand law that go beyond the custodial FSPR regime. We offer practical support to help you manage these obligations and maintain your registration in good standing. We offer a full range of ongoing risk and compliance solutions for New Zealand licensed financial institutions. Our services include, but are not limited to:

Ongoing Risk and Regulatory Compliance

• FSP Registered Custodians’ Obligations Guidance: We can advise your risk, compliance, management and other teams on meeting the requirements of the New Zealand regulatory framework and other regulatory compliance obligations. For more information, please visit our Compliance Consultancy Service page.
• Regulatory Risk and Compliance Management: We provide dedicated compliance managers to manage your overall compliance. For more information, visit our Specialised Compliance Management Solutions page.
• Compliance Assurance Solutions: As part of our compliance assurance solutions, we offer:
• Compliance Assurance Program (CAP) development and testing options
• Internal Controls Design option
• Internal Controls Testing option
• Internal AML/CFT Review option
• Statutory AML/CFT Audit option
• Compliance Training Solutions: We offer training programs to different teams on complying with:
• FSP registered custodians’ obligations for risk, regulatory compliance management, and specific trading regulations. You can visit our Compliance Training page for more information.
• FSP registered custodians’ AML/CFT obligations and operational best practices for fraud prevention. You can visit our AML/CFT Training page for more information.
• Crisis Management Planning: We can develop proactive strategies to manage potential compliance crises effectively.
• Anti-Money Laundering (AML) and Counter Terrorist Financing Solutions: We provide a full range of AML/CFT solutions for New Zealand financial institutions. For more information, visit our Specialised AML/CFT Solutions page.
• Advanced Compliance Technologies: We can assist you with selecting and integrating advanced technology solutions, such as compliance automation tools and regulatory technology (RegTech), to streamline compliance processes without disrupting operations.
• Risk and Compliance Framework Adjustments: Including adjustments to risk management frameworks (RMFs), compliance monitoring programs (CMPs), compliance management frameworks (CMFs), and other core procedures and policies to align them with:
• new business goals
• regulatory changes
• changes in your operations
• evolving market conditions
• changes in stakeholders’ risk appetites (your banking partners, insurance companies, liquidity providers, etc.).

 

Related Services

We assist in obtaining New Zealand custodians’ FSP registration equivalents in the following jurisdictions:

• Australia: For more information on the Australian equivalent of a New Zealand custodians’ FSP registration, the custodial AFSL, you can visit our AFSL Solutions page for Custodians.
• Singapore: For more information on the Singapore equivalent of a New Zealand custodians’ FSP registration, the custodial services authorisation under the Capital Markets Services Licence (CMSL), you can visit our CMS Licence page. For equivalents related to digital assets custody, you can visit our Major Payment Institution Licence page or Singaporean Standard Payment Institution Licence page. Another option includes a Trust Business Licence under the Trust Companies Act.
• United Kingdom: For more information on the UK equivalent of a New Zealand custodians’ FSP registration, the custody services permission issued by the Financial Conduct Authority (FCA), you can visit our dedicated page on Custody Services Permission under the FCA Authorisation.
• Prominent Financial Centres and Offshore Tax Havens: We also offer licensing solutions for regulated custodial service providers in the prominent financial centres and offshore tax havens, including but not limited to:

• Cayman Islands
• Bermuda
• British Virgin Islands