Bermuda: Updated CRS independence compliance review guidelines
Procedures to be followed when a reporting financial institution receives a notice to undertake a CRS review
Updated CRS independence compliance review guidelines
The Bermuda Ministry of Finance on 15 May 2024 issued an updated version of the common reporting standard (CRS) independent compliance review guidelines (version 2.0) that outlines the procedures to be followed when a Bermuda reporting financial institution receives a notice to undertake a CRS review.
The guidelines detail the Ministry’s expectations for the information that needs to be included in each CRS review report submitted, and contains the following updates:
- Under Section 2 (Approach and Risk Assessment): A new non-exhaustive risk-factor, “Notifications of non-compliance or suspected non-compliance with international FATCA or AEOI standards” has been added, which the Ministry will consider when assessing non-compliance by reporting financial institutions.
- Under Section 3 (Review Requirements and Procedures): A new clause has been added under the general requirements and guidance section. It notes that if the reporting financial institution selected for review is a trustee responsible for due diligence and reporting for one or more trustee-documented trusts (TDTs) and their underlying entities, the CRS review must cover all such TDTs and entities, and this needs to be included in the statistical sampling plan when applicable.
The section on completeness of CRS filings has been updated to note that reporting financial institutions must comply with the CRS requirements to collect tax identification numbers (TINs) and dates of birth, along with using reasonable efforts for pre-existing accounts lacking this information.
Read a May 2024 report prepared by the KPMG member firm in Bermuda
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