Financial Crime World

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Bermuda’s Common Reporting Standard (CRS) Regulations for Financial Institutions

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General Requirements


  • Trustees reporting on behalf of Trustee Documented Trusts (TDTs) must submit a separate nil return if the TDT does not maintain any reportable accounts.
  • Bermuda Financial Institutions can rely on third-party service providers to fulfill due diligence and reporting obligations, but they remain ultimately responsible.

Due Diligence Modifications


Choosing Modified Due Diligence Rules

  • Bermuda Financial Institutions can choose to apply modified due diligence rules, including applying New Account procedures to Pre-existing accounts or High Value account procedures to Lower Value accounts.
  • The residence address test and electronic record search are available for Lower Value Accounts, with the option to elect either or both.

Threshold Exemption


Eligibility Criteria

  • Financial Institutions can apply a threshold exemption for reviewing, identifying, and reporting Pre-existing Entity Accounts if the account balance does not exceed USD 250,000 as at December 31, 2015.
  • The exemption applies until the account balance exceeds USD 250,000 as at December 31 of a subsequent calendar year.

Group Cash Value Insurance Contracts or Group Annuity Contracts


Eligibility Criteria

  • A Bermuda Financial Institution can treat an account that is a Group Cash Value Insurance Contract or Group Annuity Contract as non-reportable if it meets specific requirements, including having 25 or more employees/certificate holders and aggregate amounts payable not exceeding USD 1,000,000.

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