Recommendations:
Estonia should review its systems and procedures to sort, prepare and validate the information to ensure they meet the requirements of the AEOI Standard.
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, Estonia linked to the CTS and the CCN which is used for the purposes of exchanges within the EU.
Based on these findings it was concluded that Estonia is fully meeting expectations in relation to agreeing and using appropriate transmission methods with each of its partners. Estonia 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 Estonia’s exchange partners did not raise any concerns with respect to timeliness of the exchanges by Estonia and therefore with respect to Estonia’s implementation of this requirement.
Based on these findings it was concluded that Estonia is fully meeting expectations in relation to exchanging the information in a timely manner. Estonia 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 Estonia’s exchange partners did not raise any concerns with respect to Estonia’s use of the agreed transmission methods and therefore with Estonia’s implementation of this requirement.
Based on these findings it was concluded that Estonia is fully meeting expectations in relation to sending the information in accordance with the agreed transmission methods and encryption standards. Estonia is therefore 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.
Findings:
Two exchange partners highlighted delays in the sending of status messages by Estonia, representing 2% of its partners. It was noted that Estonia appears to be successfully addressing the issues to ensure that status messages are sent in accordance with the requirements.
Based on these findings it was concluded that, overall, Estonia is meeting expectations in relation to the receipt of the information. It was noted that there is room for improvement with respect to ensuring that status messages are sent in a timely manner in all cases. Estonia is encouraged to continue to ensure the ongoing effectiveness of its implementation, including in relation to the area highlighted.
Recommendations:
Estonia should ensure that it sends status messages to all of its exchange partners in a timely manner.
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:
Estonia 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 Estonia’s exchange partners and therefore with respect to Estonia’s implementation of these requirements.
Based on these findings it was concluded that Estonia appears to be meeting expectations in relation to responding to notifications from exchange partners and the sending of corrected, amended or additional information. Estonia is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.