On January 27, 2022, Guernsey Revenue Service announced an extension for reporting the failure to obtain a valid self-certification. The first reporting date has been extended from January 31, 2022 to March 31, 2022 for both new and pre-existing accounts.
Self-Reporting Failed Self-Certs
If a Financial Institution (FI) has not been able to validate a self-certification for a New Account within 90-days of the account being opened, the FI must report the account to the Guernsey Revenue Service “immediately”. This means the FI must report the lack of validated self-certification on day 91 after account opening except if day 91 falls in January of any year. In this situation, the lack of validated self-certification must be reported by January 31 of that year.
The deadline for an FI to self-report the lack of validated self-certification on a Pre-Existing Account are:
If the trigger event leading to a missing or failed self-certification occurred prior to January 1, 2022 and the self-certification remains unresolved the FI must submit a report to the Guernsey Revenue Service on or before March 31, 2022; and
If the trigger event leading to a missing or failed self-certification occurred on or after January 1, 2022 and the self-certification remains unresolved at the later of the end of the calendar year or 90-days from the date of discovery, then the FI must submit a report to the Guernsey Revenue Service:
on or before January 31 in the following year, OR
on or before the 91st day of discovery, whichever is the later.
The self-reporting must be done through the IGOR portal.
Freezing Order
Guernsey will not automatically issue an order to the FI to freeze a customer account because the FI reports a missing/failed self-certification. However, this enforcement action is available to the Guernsey Revenue Service.
For assistance, please contact me via my contact page or at elizabeth@elizabethmcmorrowlaw.com.