Rating: Partially Compliant
Grenada’s implementation of the AEOI Standard is partially compliant with respect to exchanging the information effectively in practice and in a timely manner. More specifically, while Grenada is meeting expectations with respect to sorting, preparing and validating the information (SR 2.4) and providing corrections, amendments or additions to the information (SR 2.9), there are significant issues with respect to Grenada correctly transmitting the information and in a timely manner (SRs 2.5 – 2.8). Grenada should continue its implementation process to ensure its effectiveness, including by addressing the recommendations made.
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:
Three exchange partners highlighted particular issues with respect to preparation and format of the information sent by Grenada (representing 4% of its partners). These generally related to either incorrect reporting periods or schema errors. More generally, three (or 4%) of Grenada’s exchange partners reported rejecting more than 50 of the files received due to the technical requirements not being met. This is broadly in line with the general experience of other jurisdictions. It was noted that Grenada has not yet addressed all of the issues.
Based on these findings it was concluded that, overall, Grenada is meeting expectations in relation to sorting, preparing and validating the information. Grenada is therefore encouraged to continue its implementation process accordingly, including in relation to the area highlighted.
Recommendations:
Grenada 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, Grenada linked to the CTS.
Based on these findings it was concluded that Grenada is fully meeting expectations in relation to agreeing and using appropriate transmission methods with each of its partners. Grenada 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:
Five exchange partners highlighted delays in the sending of information by Grenada (representing 7% of its partners). This represents a very high proportion of exchange partners. Furthermore, three partners stated that the information has still not been received. It was noted that Grenada has still not yet sent all of the status messages due to be sent in 2021.
Based on these findings it was concluded that Grenada is partially meeting expectations in relation to exchanging the information in a timely manner. However, significant issues have been identified, including with respect to the timeliness of the exchanges made. Grenada should continue its implementation process to ensure its effectiveness, including by addressing the recommendation made.
Recommendations:
Grenada should ensure that 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 Grenada’s exchange partners did not raise any concerns with respect to Grenada’s use of the agreed transmission methods and therefore with Grenada’s implementation of this requirement.
Based on these findings it was concluded that Grenada is fully meeting expectations in relation to sending the information in accordance with the agreed transmission methods and encryption standards. Grenada 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:
Nine of Grenada’s exchange partners (representing 10% of its partners) highlighted delays in the sending of status messages by Grenada. This represents a relatively high proportion of partners. It was noted that five partners stated that the status messages had not yet been received. These issues appear to have not yet been resolved.
Based on these findings it was concluded that Grenada 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 its exchange partners in a timely manner. Grenada should continue its implementation process to ensure its effectiveness, including by addressing the recommendation made.
Recommendations:
Grenada 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:
Grenada 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 Grenada’s exchange partners and therefore with respect to Grenada’s implementation of these requirements.
Based on these findings it was concluded that Grenada appears to be meeting expectations in relation to responding to notifications from exchange partners and the sending of corrected, amended or additional information. Grenada is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.