Based on these findings it was concluded that, overall, Costa Rica is meeting expectations in relation to sorting, preparing and validating the information. Costa Rica is encouraged to continue its implementation process accordingly, including in relation to the area highlighted.
Recommendations:
Costa Rica should continue to work with its exchange 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, Costa Rica linked to the CTS.
Based on these findings it was concluded that Costa Rica is fully meeting expectations in relation to agreeing and using appropriate transmission methods with each of its partners. Costa Rica 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:
One exchange partner highlighted delays in the sending of information by Costa Rica. This partner stated that the corrected information has still not been received, including information that was due to be exchanged in prior years in some cases, Costa Rica is working to address the issue.
Based on these findings it was concluded that, overall, Costa Rica is meeting expectations in relation exchanging information in a timely manner. It was also noted that there is room for improvement with respect to sending corrected information to all exchange partners. Costa Rica is encouraged to continue to ensure the ongoing effectiveness of its implementation, including in relation to the area highlighted.
Recommendations:
Costa Rica should ensure it sends information to all of its exchange 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 Costa Rica’s exchange partners did not raise any concerns with Costa Rica’s use of the agreed transmission methods and therefore with Costa Rica’s implementation of the requirement.
Based on these findings it was concluded that Costa Rica is fully meeting expectations in relation to sending the information in accordance with the agreed transmission methods and encryption standards. Costa Rica 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:
31 exchange partners highlighted delays in the sending of status messages by Costa Rica, representing 41% of its partners. This represents a very high proportion of partners and it has not improved over time. Cost Rica 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 Costa Rica is not meeting expectations in relation to the receipt of the information. More specifically, fundamental issues have been identified, including with respect to sending status messages on receipt of files. Costa Rica is encouraged to continue to ensure the ongoing effectiveness of its implementation, including in relation to the area highlighted.
Recommendations:
Costa Rica should ensure 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:
Costa Rica 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 Costa Rica’s exchange partners and therefore with respect to Costa Rica’s implementation of these requirements.
Based on these findings it was concluded that Costa Rica appears to be fully meeting expectations in relation to responding to notifications from exchange partners and the sending of corrected, amended, or additional information. Costa Rica is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.