Rating: On Track
Vanuatu’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 Vanuatu exchanges information non-reciprocally, so does not receive information. Vanuatu 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 Vanuatu’s exchange partners did not raise any specific concerns with respect to their ability to process the information received from Vanuatu and therefore with respect to Vanuatu’s implementation of these requirements. Two (or 3%) of Vanuatu’s exchange partners reported rejecting more than 25% of the files received due to the technical requirements not being met, although they did not reject over 50% of files. This is broadly in line with the general experience of other jurisdictions. Vanuatu stated that the returned files have not yet been verified and corrected.
Based on these findings it was concluded that, overall, Vanuatu is meeting expectations in relation to sorting, preparing and validating the information. It was also noted that there is room for improvement with respect to the resubmission of corrected files. Vanuatu is therefore encouraged to continue its implementation process accordingly, including in relation to the area highlighted.
Recommendations:
Vanuatu should continue to engage with its partners to address the issues raised.
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, Vanuatu linked to the Common Transmission System.
Based on these findings it was concluded that Vanuatu is fully meeting expectations in relation to agreeing and using appropriate transmission methods with each of its partners. Vanuatu 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:
Three exchange partners highlighted delays in the sending of information by Vanuatu (representing 5% of its partners). This represents a relatively high proportion of exchange partners. Furthermore, two partners stated that the information has still not been received. It was noted that Vanuatu successfully addressed all of the issues and sent the information as soon as possible thereafter.
Based on these findings it was concluded that Vanuatu is fully meeting expectations in relation to exchanging the information in a timely manner. Vanuatu 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 Vanuatu’s exchange partners did not raise any concerns with respect to Vanuatu’s use of the agreed transmission methods and therefore with Vanuatu’s implementation of this requirement.
Based on these findings it was concluded that Vanuatu is fully meeting expectations in relation to sending the information in accordance with the agreed transmission methods and encryption standards. Vanuatu 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.
It should be noted that, as Vanuatu 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:
While it is unclear whether Vanuatu’s approach will ensure that corrected, amended or additional information is provided in a timely manner, it has not been tested and no such concerns were raised by Vanuatu’s exchange partners and therefore with respect to Vanuatu’s implementation of these requirements.
Based on these findings it was concluded that Vanuatu appears to be meeting expectations in relation to responding to notifications from exchange partners and the sending of corrected, amended or additional information. Vanuatu is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.