Common Reporting Standard (CRS) Compliance Certification Form for Financial Institutions in Bermuda
Excluded Accounts
Accounts meeting the formal CRS definition of ‘Excluded Account’ are not required to be reported. FIs must confirm whether they had any Excluded Accounts during the reporting period.
- Confirmation requirement: FIs must confirm whether they had any Excluded Accounts during the reporting period.
- Explanation for uncertainty: If unable to confirm, an explanation is required, and the FI may face follow-up from the Ministry.
Financial Accounts
Joint accounts should be treated as one Financial Account for CRS purposes. Non-Reportable accounts are not required to be reported unless all joint account holders are non-reportable.
- Treatment of joint accounts: Joint accounts should be treated as one Financial Account for CRS purposes.
- Reporting requirement: Non-Reportable accounts are not required to be reported unless all joint account holders are non-reportable.
Policies & Procedures
FIs must have written policies and procedures in place to identify Reportable Accounts and other related information. A copy of these policies and procedures must be attached to the CRS Compliance Form.
- Written policies and procedures: FIs must have written policies and procedures in place to identify Reportable Accounts and other related information.
- Attachment requirement: A copy of these policies and procedures must be attached to the CRS Compliance Form.
Due Diligence
Self-certifications are a mandatory requirement for new accounts within 90 days. If self-certifications were not obtained, an explanation is required. FIs must also collect TINs or dates of birth for preexisting individual accounts and be prepared to evidence reasonable efforts made to do so.
- Self-certification requirement: Self-certifications are a mandatory requirement for new accounts within 90 days.
- Explanation for non-compliance: If self-certifications were not obtained, an explanation is required.
- Collection of TINs or dates of birth: FIs must also collect TINs or dates of birth for preexisting individual accounts and be prepared to evidence reasonable efforts made to do so.
Outsourcing
FIs that outsource any portion of their due diligence and/or reporting procedures to a third-party service provider must answer “Yes” to this question. The FI remains responsible for ensuring the outsourced functions are undertaken in accordance with CRS requirements.
- Outsourcing requirement: FIs that outsource any portion of their due diligence and/or reporting procedures to a third-party service provider must answer “Yes” to this question.
- Responsibility for outsourcing: The FI remains responsible for ensuring the outsourced functions are undertaken in accordance with CRS requirements.
Additional Guidance
Deregistered entities will not be required to complete the CRS Compliance Form for 2020, but will need to do so for future years as a prerequisite for deactivation. Investment managers and advisors that meet certain conditions may be exempt from submitting the CRS Compliance Form.
- Exemption for deregistered entities: Deregistered entities will not be required to complete the CRS Compliance Form for 2020, but will need to do so for future years as a prerequisite for deactivation.
- Exemption for investment managers and advisors: Investment managers and advisors that meet certain conditions may be exempt from submitting the CRS Compliance Form.