Rating: On Track
Argentina’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), most of the requirements in relation to correctly transmitting the information in a timely manner (SRs 2.5 – 2.8) and providing corrections, amendments or additions to the information (SR 2.9). However, some issues were found with respect to the sending of status messages (SR 2.8). Argentina 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:
Feedback from Argentina’s exchange partners did not raise any specific concerns with respect to their ability to process the information received from Argentina and therefore with respect to Argentina’s implementation of these requirements. More generally, two (or 3%) of Argentina’s exchange partners reported rejecting 50% or more of the 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 Argentina has already successfully addressed all of the issues.
Based on these findings it was concluded that Argentina is fully meeting expectations in relation to sorting, preparing and validating the information. Argentina 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, Argentina linked to the CTS.
Based on these findings it was concluded that Argentina is fully meeting expectations in relation to agreeing and using appropriate transmission methods with each of its partners. Argentina 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 Argentina’s exchange partners did not raise any concerns with respect to timeliness of the exchanges by Argentina and therefore with respect to Argentina’s implementation of this requirement.
Based on these findings it was concluded that Argentina is fully meeting expectations in relation to exchanging the information in a timely manner. Argentina is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.
SR 2.7Jurisdictions should send the information in accordance with the agreed transmission methods and encryption standards.
Findings:
Feedback from Argentina’s exchange partners did not raise any concerns with respect to Argentina’s use of the agreed transmission methods and therefore with Argentina’s implementation of this requirement.
Based on these findings it was concluded that Argentina is fully meeting expectations in relation to sending the information in accordance with the agreed transmission methods and encryption standards. Argentina 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.
Findings:
Five exchange partners highlighted delays in the sending of status messages by Argentina, representing 5% of its partners. This represents a relatively high proportion of partners and has not improved over time. For the 2021 exchanges, Argentina noted that it experienced issues with the implementation of a system to perform automatic matching that had impacted the sending of status messages. The implementation of this system has been concluded and the issues with sending status messages have been solved. Argentina has also successfully addressed most of the issues raised by peers, including issues related to previous exchange cycles, and is working to resolve the remaining issues.
Based on these findings it was concluded that, overall, Argentina is meeting expectations in relation to the receipt of the information. It was also noted that there is room for improvement with respect to the sending of status messages in a timely manner. Argentina is encouraged to continue to ensure the ongoing effectiveness of its implementation, including by addressing the recommendation made.
Recommendations:
Argentina should continue to engage with its exchange partners to address the issues raised.
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:
Argentina 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 Argentina’s exchange partners and therefore with respect to Argentina’s implementation of these requirements.
Based on these findings it was concluded that Argentina appears to be meeting expectations in relation to responding to notifications from exchange partners and the sending of corrected, amended or additional information. Argentina is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.