Based on these findings it was concluded that the Seychelles is not meeting expectations in relation to sorting, preparing and validating the information. More specifically, fundamental issues have been identified, including with respect to the validation of the information. The Seychelles should therefore continue its implementation process accordingly, including by addressing the recommendations made.
Recommendations:
The Seychelles should continue to work with its exchange partners to address the issues raised.
The Seychelles should review its procedures for sorting, preparing and validating 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, the Seychelles linked to the CTS.
Based on these findings it was concluded that the Seychelles is fully meeting expectations in relation to agreeing and using appropriate transmission methods with each of its partners. The Seychelles 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:
10 exchange partners highlighted delays in the sending of information by the Seychelles (representing 14% of its partners). This represents a very high proportion of exchange partners and has not improved over time. The Seychelles wrote to the Competent Authorities of its partners to inform them that a delay in sending the 2021 information would take place due to a change in the internal reporting system. It was noted that the Seychelles successfully addressed all of the issues and sent the information as soon as possible thereafter.
Based on these findings it was concluded that the Seychelles is partially meeting expectations in relation to exchanging the information in a timely manner. More specifically, significant issues have been identified, including with respect to sending of the information to all exchange partners in a timely manner. The Seychelles should continue its implementation process to ensure its effectiveness, including by addressing the recommendation made.
Recommendations:
The Seychelles should ensure that it sends information to all of its 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 the Seychelles’ exchange partners did not raise any concerns with respect to the Seychelles’ use of the agreed transmission methods and therefore with the Seychelles’ implementation of this requirement.
Based on these findings it was concluded that the Seychelles is fully meeting expectations in relation to sending the information in accordance with the agreed transmission methods and encryption standards. The Seychelles is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendation 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:
Nine exchange partners highlighted delays in the sending of status messages by the Seychelles, representing 10% of its partners. This represents a relatively high proportion of partners. It was noted that the Seychelles appears to be addressing the issues to ensure that status messages are sent in accordance with the requirements. However, the Seychelles has still not yet sent some of the status messages due to be sent in 2021.
Based on these findings it was concluded that the Seychelles is partially meeting expectations in relation to the receipt of the information. However, significant issues have been identified, including with respect to the sending of status messages to the sending jurisdictions. The Seychelles should continue its implementation process to ensure its effectiveness, including by addressing the recommendation made.
Recommendations:
The Seychelles should ensure it consistently 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:
The Seychelles 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 the Seychelles’ exchange partners and therefore with respect to the Seychelles’ implementation of these requirements.
Based on these findings it was concluded that the Seychelles appears to be meeting expectations in relation to responding to notifications from exchange partners and the sending of corrected, amended or additional information. The Seychelles is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendation made.