On March 31, 2022, the States of Guernsey Revenue Service published Common Reporting Standard (CRS) and Foreign Account Tax Compliance Act (FATCA) Compliance Information Notice 2. Among a number of updates and links to guidance, the Compliance Information Notice identified a few key areas that require attention:
- Data accuracy. Filers should review data prior to submission for omissions, inaccuracies, or anomalies, specifically country codes, dates of birth, and financial account addresses. Further, review that the use of ‘undocumented’ is applied correctly.
- Training. Recommendation that financial institutions implement a training program for the CRS and FATCA for all employees. This training must remain current on all details related to the automatic exchange of information (AEoI).
- Governance. Expectation that a Board or Senior Management equivalent is aware of their AEoI responsibilities and obligations – especially with respect to submitting complete and accurate data. This includes implementing procedures and having controls in place for monitoring AEoI obligations.
- Revenue Service Checks. The Guernsey Revenue Service expects that financial institutions have implemented robust controls and procedures for reporting accurate information. As such, the Revenue Service’s AEoI Team will undertake a range of activities to review for effective compliance.
- 2022 Thematic Review. The Guernsey Revenue Service intends to conduct a thematic review of a cross section of financial institutions to review information on the governance and training with respect to the CRS and FATCA.
Check out the Compliance Information Notice 2 here:
Make sure to follow Comply Exchange for more industry updates and subscribe to the Comply Catch-up for a full industry round-up at the end of each month!