Rating: On Track
Bermuda’s implementation of the AEOI Standard is on track with respect to exchanging the information effectively in practice, including in relation to sorting, preparing and validating the information (SR 2.4), correctly transmitting the information in a timely manner (SRs 2.5 – 2.7) and providing corrections, amendments or additions to the information (SR 2.9). The requirements in relation to the receipt of the information (SR 2.8) have not been assessed as Bermuda exchanges information non-reciprocally, so does not receive information. Bermuda is encouraged to continue its implementation process accordingly, to ensure its ongoing effectiveness.
SR 2.4 Jurisdictions should sort, prepare and validate the information in accordance with the CRS XML Schema and the associated requirements in the CRS XML Schema User Guide and the File Error and Correction-related validations in the Status Message User Guide (i.e. the 50000 and 80000 range).
Findings:
One exchange partner highlighted particular issues with respect to preparation and format of the information sent by Bermuda related to a correction file for an unknown record. More generally, one of Bermuda’s exchange partners reported rejecting more than 25% of the files received, but not more than 50%, due to the technical requirements not being met. This is a relatively low amount when compared to other jurisdictions. It was noted that Bermuda has already solved the issue raised.
Based on these findings it was concluded that Bermuda is fully meeting expectations in relation to sorting, preparing and validating the information. Bermuda is therefore encouraged to continue its implementation process accordingly.
Recommendations:
No recommendations made.
SR 2.5 Jurisdictions should agree and use, with each exchange partner, transmission methods that meet appropriate minimum standards to ensure the confidentiality and integrity of the data throughout the transmission, including its encryption to a minimum secure standard.
Findings:
In order to put in place an agreed transmission method that meets appropriate minimum standards in confidentiality, integrity of the data and encryption for use with each of its exchange partners, Bermuda linked to the CTS.
Based on these findings it was concluded that Bermuda is fully meeting expectations in relation to agreeing and using appropriate transmission methods with each of its partners. Bermuda is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.
SR 2.6 Jurisdictions should carry out all exchanges annually within nine months of the end of the calendar year to which the information relates.
Findings:
Feedback from Bermuda’s exchange partners did not raise any concerns with respect to timeliness of the exchanges by Bermuda and therefore with respect to Bermuda’s implementation of this requirement.
Based on these findings it was concluded that Bermuda is fully meeting expectations in relation to exchanging the information in a timely manner. Bermuda is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.
SR 2.7 Jurisdictions should send the information in accordance with the agreed transmission methods and encryption standards.
Findings:
Feedback from Bermuda’s exchange partners did not raise any concerns with respect to Bermuda’s use of the agreed transmission methods and therefore with Bermuda’s implementation of this requirement.
Based on these findings it was concluded that Bermuda is fully meeting expectations in relation to sending the information in accordance with the agreed transmission methods and encryption standards. Bermuda is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.
SR 2.8 Jurisdictions should have the systems in place to receive information and, once it has been received, should send a status message to the sending jurisdictions in accordance with the CRS Status Message XML Schema and the related User Guide.
It should be noted that, as Bermuda exchanges information on a non-reciprocal basis and does not therefore receive information, it is not required to have in place systems to receive the information and provide status messages. SR 2.8 has therefore not been assessed in this case.
Findings:
Not applicable.
Recommendations:
Not applicable.
SR 2.9 Jurisdictions should respond to a notification from an exchange partner as referred to in Section 4 of the Model CAA (which may include Status Messages) in accordance with the timelines set out in the Commentary to Section 4 of the Model CAA. In all other cases, jurisdictions should send corrected, amended or additional information received from a Reporting Financial Institution as soon as possible after it has been received.
Findings:
Bermuda appears ready to respond to notifications and to provide corrected, amended or additional information in a timely manner and no such concerns were raised by Bermuda’s exchange partners and therefore with respect to Bermuda’s implementation of these requirements.
Based on these findings it was concluded that Bermuda appears to be fully meeting expectations in relation to responding to notifications from exchange partners and the sending of corrected, amended or additional information. Bermuda is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.