30 January 2025
J M
[FYI request #33020 email]
DOIA-REQ-0024677
Tēnā koe J M
Thank you for your email of 27 November 2025 to the Ministry of Business, Innovation and
Employment requesting, under the Official Information Act 1982 (the Act), the fol owing:
Please provide the fol owing information held by Immigration New Zealand for the period 1
January 2012 til now concerning Guosen (Guosen Securities) and the Guosen QDI product:
1. Documents submitted by Guosen to INZ All documents and submission bundles provided by
Guosen to INZ regarding the QDI product, including investment report templates and samples,
product descriptions, custodial/clearing arrangements, banking/swift evidence, and any
materials addressing verification/traceability, source of funds, control/custody, or use of the
trading bank system to transfer nominated funds - including how the use of the trading bank
system is assessed or evidenced (e.g. criteria, procedures, and proof used to confirm that
transfers are conducted through the banking system).
2. Communications between INZ and Guosen All communications (emails, letters, meeting
minutes, teleconference notes, file notes) between INZ and Guosen relating to: a) the format
and content of investment reports, b) how the product met verification/traceability
requirements and the “trading bank system” requirement, c) assessment of the product’s
eligibility against the relevant residence instructions.
3. INZ internal records about Guosen QDI Internal INZ policy notes, guidance, briefings, aide-
memoires, file notes, and decision records that discuss or evaluate the Guosen QDI product
with respect to: a) verification/traceability of funds and investment positions, b) whether funds
were originally transferred to New Zealand through the trading bank system, c) any risks,
concerns, or resolution steps agreed with Guosen, d) any change of position or rationale for
shifting views (if applicable).
4. The first approval involving a Guosen QDI client (circa 2016) The decision record
(reasoning/notes) and conditions relevant to the QDI product in the first INZ approval
involving a Guosen QDI client in or around 2016. Please redact personal identifiers under
s9(2)(a).Please confirm receipt. If any material is withheld, please state the OIA grounds and
provide the rest. Let me know first if charges or narrowing are needed. I look forward to your
timely response.
On 13 January 2026, we wrote to advise you that MBIE had decided to extend the period of time available
to make a decision on your request under section 15A(1)(b) of the Act, as consultations necessary to
make a decision on your request were such that a proper response to the request cannot reasonably be
made within the original time limit. We advised that MBIE would notify you of a decision on your request
no later than 30 January 2026.
Our Response
Questions 1 and 3
Please refer to Appendix A for the documents in scope of your request as outlined in the table below:
Document
Decision
Assessment templates
Released in full
Internal INZ email chain
9(2)(a)
9(2)(h)
Guosen-Cedar-NZAM - QDI project – September 2014
Released in full
QDI NZ Fund Operational Manual 2014
Released in full
Memo: Guosen QDI NZD Fund – 8 October 2014
Released in full
Please be advised that we have withheld some information from the above documents under the
fol owing sections of the Act:
• 9(2)(a) to protect the privacy of natural persons
• 9(2)(h) to maintain legal professional privilege
We are also withholding four other email chains in ful under section 9(2)(h) of the Act as it is necessary
to withhold these documents in full to maintain legal professional privilege.
Question 2
We are refusing your request for the communications between Immigration New Zealand (INZ) and
Guosen – question 2 of the request - under section 18(f) of the Act as the information requested
cannot be made available without substantial collation or research. In particular, we would require
manually research and collate 18,396 emails for the whole period. If we are to narrow the timeframe
to 2012-2016, our search result stil return more than 2,000 records.
In accordance with section 18A of the Act, I have considered whether fixing a charge under section 15
or extending the time limit under section 15A would enable the request to be granted but it is my view
it would not. In accordance with section 18B of the Act, I have considered whether consulting with
you would remove the reason for refusal, however, in my view it would not.
Question 4
We confirm that the first application where the applicant completed investments into Guosen QDI
was approved in April 2016 and the resident visa granted in May 2016. Please refer to Appendix B for
the anonymised assessment notes. We have withheld all private information under section 9(2)(a) of
the Act to protect the privacy of natural persons.
Throughout the response, where information is withheld under section 9 of the Act, I do not consider
that the withholding of this information is outweighed by public interest considerations in making the
information available.
You have the right to seek an investigation and review by the Ombudsman of this decision. Information
about how to make a complaint is available at
www.ombudsman.parliament.nz or freephone 0800
802 602.
If you wish to discuss any aspect of your request or this response, please contact
[email address].
Nāku noa, nā
Jock Gilray
Director Visa
Immigration New Zealand
Ministry of Business, Innovation & Employment
