Rating: Partially Compliant
Dominica’s implementation of the AEOI Standard is partially compliant with respect to exchanging the information effectively in practice and in a timely manner. More specifically, while Dominica is meeting expectations with respect to sorting, preparing and validating the information (SR 2.4), and providing corrections, amendments or additions to the information (SR 2.9), there have been significant issues with respect to Dominica correctly transmitting the information and in a timely manner (SRs 2.5 – 2.7). This reflects the significant delay in commencing exchanges, including the exchanges commencing later than nine months after the end of calendar year to which the first information reported by Reporting Financial Institutions related. It is noted that this issue appears to be addressed for future exchanges. The requirements in relation to the receipt of the information (SR 2.8) have not been assessed as Dominica exchanges information non-reciprocally, so does not receive information. While Dominica has shown improvement over time, Dominica should continue its implementation process to ensure its effectiveness, including by addressing the recommendation made.
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 a particular issue with respect to preparation and format of the information sent by Dominica. This related to the file preparation requirements. More generally, two (or 4%) of Dominica’s exchange partners reported rejecting more than 25% of the files received, of which one reported rejecting more than 50% of files received, due to the technical requirements not being met. This is broadly in line with the general experience of other jurisdictions. It was noted that Dominica has already successfully addressed the issue raised.
Based on these findings it was concluded that Dominica is fully meeting expectations in relation to sorting, preparing and validating the information. Dominica is encouraged to continue its implementation process accordingly, to ensure its ongoing effectiveness.
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, Dominica linked to the CTS.
Based on these findings it was concluded that Dominica is fully meeting expectations in relation to agreeing and using appropriate transmission methods with each of its partners. Dominica 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:
Dominica committed to commence exchanges under the AEOI Standard in 2018 but its implementation of the technical requirements was significantly delayed. Dominica commenced exchanges of information under the AEOI Standard in December 2021, exchanging information that related to the 2020 calendar year. Dominica now has systems in place to receive information from Reporting Financial Institutions and to report the information to partners within nine months of the end of the calendar year, meaning that the issues that prevented timely reporting should now be addressed for future exchanges.
Based on these findings it was concluded that, while the issues should be addressed for future exchanges, Dominica is so far not meeting expectations in relation to exchanging the information in a timely manner. More specifically, fundamental issues have been identified in relation to the exchanges until 2021. Dominica should continue its implementation process to ensure its effectiveness, including by addressing the recommendations made.
Recommendations:
Dominica should ensure it sends information to all of its exchange partners in a timely manner.
SR 2.7 Jurisdictions should send the information in accordance with the agreed transmission methods and encryption standards.
Findings:
Feedback from Dominica’s exchange partners did not raise any concerns with respect to Dominica’s use of the agreed transmission methods and therefore with Dominica’s implementation of this requirement.
Based on these findings it was concluded that Dominica is fully meeting expectations in relation to sending the information in accordance with the agreed transmission methods and encryption standards. Dominica 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 Dominica exchanges information on a non-reciprocal basis and does not 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:
Dominica 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 Dominica’s exchange partners and therefore with respect to Dominica’s implementation of these requirements.
Based on these findings it was concluded that Dominica appears to be meeting expectations in relation to responding to notifications from exchange partners and the sending of corrected, amended or additional information. Dominica is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.