Based on these findings it was concluded that, overall, Gibraltar 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 addressing the errors reported by its exchange partners in a timely manner. Gibraltar is therefore encouraged to continue its implementation process accordingly, including in relation to the area highlighted.
Recommendations:
Gibraltar should continue to work with its exchange partner 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, Gibraltar linked to the CTS.
Based on these findings it was concluded that Gibraltar is fully meeting expectations in relation to agreeing and using appropriate transmission methods with each of its partners. Gibraltar 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 Gibraltar’s exchange partners did not raise any concerns with respect to timeliness of the exchanges by Gibraltar and therefore with respect to Gibraltar’s implementation of this requirement.
Based on these findings it was concluded that Gibraltar is fully meeting expectations in relation exchanging information in a timely manner. Gibraltar 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 Gibraltar’s exchange partners did not raise any concerns with respect to Gibraltar’s use of the agreed transmission methods and therefore with Gibraltar’s implementation of this requirement.
Based on these findings it was concluded that Gibraltar is fully meeting expectations in relation to sending the information in accordance with the agreed transmission methods and encryption standards. Gibraltar 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:
Four exchange partners highlighted delays in the sending of status messages by Gibraltar, representing 4% of its partners. This represents a relatively high proportion of partners. Gibraltar 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, overall, Gibraltar 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. Gibraltar is encouraged to continue to ensure the ongoing effectiveness of its implementation, including in relation to the area highlighted.
Recommendations:
Gibraltar 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:
Gibraltar 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 Gibraltar’s exchange partners and therefore with respect to Gibraltar’s implementation of these requirements.
Based on these findings it was concluded that Gibraltar appears to be fully meeting expectations in relation to responding to notifications from exchange partners and the sending of corrected, amended or additional information. Gibraltar is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.