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  • Elizabeth A. McMorrow

New Guernsey Bulletin Mandatory Registration for Non-Reporting FIs

On December 24, 2021, Guernsey Revenue Service issued a bulletin discussing mandatory FATCA and Common Reporting Standard (CRS) registration for all Guernsey financial institutions. The Guernsey Revenue Service makes clear that effective January 1, 2022, FATCA and CRS registration in IGOR is mandatory even if the financial institution does not have a reporting obligation.


The deadline for registration is February 28, 2022. Thereafter, a Non-Reporting FI (NRFI) will have the capability to submit nil reporting and a Compliance Assurance Statement through IGOR. The Compliance Assurance Statement for NRFIs is one question:


All appropriate policies, procedures and controls were in place in order to comply with the CRS and FATCA Regulations reporting requirements for all financial accounts which it maintained and established during the reporting period.


Classification Declaration


NRFIs should check with their FATCA/CRS advisors to determine their classification prior to registering in IGOR. It is necessary to know what specific type of NRFI you are to click on the appropriate category.


Reporting FIs Compliance Assurance Statement


Guernsey has updated the CRS Compliance Assurance Statement to the following:


1. All appropriate policies, procedures and systems were in place in order to comply with the CRS Regulations reporting requirements for all financial accounts maintained and established during the reporting period.

2. The evidence used to comply with the Schedule 2 due diligence requirements has been retained and a record of the steps taken when performing due diligence reviews on accounts has been made.

3. The evidence used to comply with the due diligence requirements and a record of the steps taken when performing due diligence reviews on accounts will be retained for a minimum period of 6 years.

4. All appropriate policies, procedures and systems are in place to ensure that the tax residency information of Account Holders has been obtained for all New Accounts.

5. All reportable accounts closed during the period covered by the report have been included in the report and identified as such.

6. Only reportable accounts that comply with the “undocumented” criteria have been reported accordingly.

7. All financial accounts have been appropriately reviewed to ensure complete and accurate data has been reported in a timely manner.

8. Every reportable account submitted has been reviewed to confirm the data submitted is complete, correct and includes accurate details of all the required reportable information for the reporting period.

9. For new accounts a valid self-certification is either in place and the appropriate reporting and due diligence requirements have been met or has been reported to the Director (Revenue Service) where it has not been possible to obtain a valid self-certificate.


Guernsey has updated the FATCA Compliance Assurance Statement to the following:


1. All appropriate policies, procedures and systems were in place in order to comply with the FATCA Regulations reporting requirements for all financial accounts maintained and established during the reporting period.

2. The evidence used to comply with the due diligence requirements and a record of the steps taken when performing due diligence reviews on accounts will be retained for a minimum period of 6 years.

3. All reportable accounts closed during the reporting period have been included in the report and identified as such.

4. All reportable accounts without a TIN have been contacted and requested to provide their TIN.

5. All financial accounts have been appropriately reviewed to ensure complete and accurate data has been reported in a timely manner.

6. Every reportable account submitted has been reviewed to confirm the data submitted is complete, correct and includes accurate details of all the required reportable information for the reporting period.

7. For new accounts a valid self-certification is either in place and the appropriate reporting and due diligence requirements have been met or has been reported to the Director (Revenue Service) where it has not been possible to obtain a valid self-certificate.


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


#Guernsey #FATCA #CRS #Registration #Compliance

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