New Guernsey FATCA/CRS Compliance Statement Requirement

The Guernsey Revenue Service announced Financial Institutions (FIs) must submit Common Reporting Standard (CRS) and FATCA Compliance Statements as part of their Y2020 reporting. Through the Compliance Statement, an FI will confirm all reports submitted (including nil reports) comply with the relevant Guernsey regulations.

Assurance Points

The yet to be shared Compliance Statement will pose a series of questions requiring a Yes or No answer. If the FI answers No to a particular question, it may be required to provide a brief explanation. It will be possible to submit FATCA and CRS reporting on IGOR without completing the Compliance Statement but the reporting will be considered incomplete until the FI submits the Compliance Statement.

An FI that undertakes FATCA / CRS reporting via API will submit its reporting as normal but must also log into IGOR to submit the Compliance Statement.

Classification Declaration

Another new step in Y2020 reporting will be a classification declaration whereby the FI will indicate the type of reporting institution it is.

The FATCA Reporting FI classifications are:

• Depository Institution

• Custodial Institution

• Investment Entity

• Specified Insurance Company

The CRS Reporting FI classifications are:

• Depository Institution

• Custodial Institution

• Investment Entity [type (a)]

• Investment Entity [type (b)]

• Specified Insurance Company

• Trustee reporting for Trustee Documented Trust

Portal Reopening

The IGOR portal is scheduled to reopen on Monday, February 1, 2021 at which time FIs must use CRS XML Schema Version 2.0 and rely on CRS User Guide Version 3.0.

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

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