Rating: On Track
Greenland’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 – 2.8) and providing corrections, amendments or additions to the information (SR 2.9). Greenland 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:
One exchange partner highlighted a particular issue with respect to preparation and format of the information sent by Greenland. This issue related to the rejection of the files. None of Greenland’s exchange partners reported rejecting more than 25% of the files received. It was also noted that Greenland has already successfully addressed the issue raised.
Based on these findings it was concluded that Greenland is fully meeting expectations in relation to sorting, preparing and validating the information. Greenland 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, Greenland linked to the CTS.
Based on these findings it was concluded that Greenland is fully meeting expectations in relation to agreeing and using appropriate transmission methods with each of its partners. Greenland 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 Greenland. It was noted that Greenland successfully addressed the issue and sent the information as soon as possible thereafter.
Based on these findings it was concluded that Greenland is fully expectations in relation to exchanging the information in a timely manner. Greenland 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 Greenland’s exchange partners did not raise any concerns with respect to Greenland’s use of the agreed transmission methods and therefore with Greenland’s implementation of this requirement.
Based on these findings it was concluded that Greenland is fully meeting expectations in relation to sending the information in accordance with the agreed transmission methods and encryption standards. Greenland 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:
Three exchange partners highlighted delays in the sending of status messages by Greenland, representing 3% of its partners. It was noted that Greenland has successfully addressed one of the issues and is taking steps to address the remaining ones to ensure that status messages are sent in accordance with the requirements. Greenland has not yet sent status messages that were due to be sent in prior years, although Greenland reports that this is due to the upgrade in the XML Schema.
Based on these findings it was concluded that, overall, Greenland 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 CRS status messages in a timely manner. Greenland is encouraged to continue to ensure the ongoing effectiveness of its implementation, including by addressing the recommendation made.
Recommendations:
Greenland 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:
Greenland 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 Greenland’s exchange partners and therefore with respect to Greenland’s implementation of these requirements.
Based on these findings it was concluded that Greenland appears to be meeting expectations in relation to responding to notifications from exchange partners and the sending of corrected, amended or additional information. Greenland is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.