New Extension to Cayman CRS Compliance Form

The Department for International Tax Cooperation (DITC) announced the deadline for the first ever CRS Compliance Form is now September 15, 2021. This means that you will submit one form for your Y2019 data on September 15, 2021 and one form for your Y2020 data on the regularly scheduled deadline of September 15, 2021.

Portal Adjustments

The DITC extended the deadline to give itself more time to finalizeing the bulk upload feature. For those FIs who do not require the bulk upload feature, it is currently possible to submit your 2019 CRS Compliance Form using the online smart form in the DITC Portal.

What Is the CRS Compliance Form?

The Cayman Islands CRS Compliance Form must be submitted annually by all Cayman Islands Reporting FIs. The form is akin to the IRS FATCA RO Certification covering five areas:

• Section 1 - Financial Institution Profile Data

• Section 2 - Financial Account Data

• Section 3 - AML/KYC and Accounting

• Section 4 - CRS Process

• Section 5 - Declaration

Submission v Approval

The CRS Compliance Form declaration includes the following statement regarding the signatory: “Acknowledges that there are sanctions for providing inaccurate information to the TIA and for contravention of the CFI’s compliance and due diligence obligations.”

Your Cayman Islands DITC Portal Principal Point of Contact (PPOC) and Secondary Users have the ability to submit the CRS Compliance Form. However, it is important that your internal policies and procedures require a person at the level of a FATCA Responsible Officer to approve the submission given the potential adverse repercussions of failing to submit accurate information.

Deregistration / Deactivation

Another point to include in your internal processes is adding the CRS Compliance Form to your FI deregistration checklist. Prior to deactivating an FI account in the DITC portal, you must deregister the FI from the IRS FATCA portal, complete all FATCA/CRS returns, Cayman Islands CRS Filing Declaration, and Cayman Islands CRS Compliance Form.

For assistance, please contact me via my contact page or at elizabeth@elizabethmcmorrowlaw.com.

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