Based on these findings it was concluded that Chile is partially meeting expectations in relation to sorting, preparing and validating the information. However, significant issues have been identified, including with respect to timely responding to peer’s rejection messages. Chile should therefore continue its implementation process accordingly, including by addressing the recommendations made.
Recommendations:
Chile should continue to work with its exchange partners to address the issues raised.
Chile 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, Chile linked to the CTS.
Based on these findings it was concluded that Chile is fully meeting expectations in relation to agreeing and using appropriate transmission methods with each of its partners. Chile 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:
Four exchange partners highlighted delays in the sending of information by Chile (representing 5% of its partners). This represents a relatively high proportion of exchange partners and has not improved over time. Furthermore, all these four partners stated that the information has still not been received with respect to one or more reporting years.
Based on these findings it was concluded that Chile is not meeting expectations in relation exchanging information in a timely manner. More specifically, fundamental issues have been identified, including with respect to sending information to all peers. Chile should continue its implementation process to ensure its effectiveness, including by addressing the recommendation made.
Recommendations:
Chile should ensure it sends information to all of its exchange partners with respect to all reporting years and within the required timeframe.
SR 2.7 Jurisdictions should send the information in accordance with the agreed transmission methods and encryption standards.
Findings:
Feedback from Chile’s exchange partners did not raise any concerns with respect to Chile’s use of the agreed transmission methods and therefore with Chile’s implementation of this requirement.
Based on these findings it was concluded that Chile is fully meeting expectations in relation to sending the information in accordance with the agreed transmission methods and encryption standards. Chile 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:
Two exchange partners highlighted delays in the sending of status messages by Chile, representing 5% of its partners. Chile has still not yet sent some of the status messages due to be sent in 2021, as well as some that were due to be sent in prior years.
Based on these findings it was concluded that Chile is partially meeting expectations in relation to the receipt of the information. However, significant issues have been identified, including with respect to sending status messages to all its partners. Chile should continue its implementation process to ensure effectiveness, including by addressing the recommendation made.
Recommendations:
Chile should ensure it sends status messages to all 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:
Feedback from Chile’s exchange partners did not raise any concerns with respect to Chile’s response to notifications or provision of corrected, amended or additional information and therefore with respect to Chile’s implementation of these requirements. Chile has still no procedures in place to address notifications received from partners, and might encounter difficulties fulfilling this requirement.
Based on these findings it was concluded that, overall, Chile appears to be meeting expectations in relation to responding to notifications from exchange partners and the sending of corrected, amended or additional information. It was also noted that there is room for improvement with respect to having in place procedures to respond to notifications from partners. Chile is encouraged to continue to ensure the ongoing effectiveness of its implementation, including in relation to the area highlighted.
Recommendations:
Chile should develop and implement effective procedures to effectively respond to partners when they notify Chile of errors or suspected non-compliance by its Reporting Financial Institutions.