You are required, under section 26(1) of the AML/CFT Act, to take “reasonable steps” to determine whether your customer or any beneficial owner is a PEP. This is required as soon as is practicable after you have established a business relationship or undertaken an occasional transaction.
This should be done on in line with a risk-based approach and does not require you to undertake extensive checking of every customer – a simple open-source internet search may be enough for lower-risk customers. Bear in mind that “reasonable steps” does not mean “no steps”, even New Zealand Citizens and Passport holders may, for example, have familial links or associations that make them a PEP.