Rating: On Track
Latvia’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). Latvia 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:
Feedback from Latvia’s exchange partners did not raise any specific concerns with respect to their ability to process the information received from Latvia and therefore with respect to Latvia’s implementation of these requirements. Two (or 3%) of Latvia’s exchange partners reported rejecting more than 25% of files received, due to the technical requirements not being met, of which none reported rejecting more than 50% of files. This is broadly in line with the general experience of other jurisdictions. It was noted that Latvia is in the process of addressing the issues.
Based on these findings it was concluded that, overall, Latvia 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 file rejections. Latvia is therefore encouraged to continue its implementation process accordingly, including in relation to the area highlighted.
Recommendations:
Latvia should continue to engage with its 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, Latvia linked to the CTS and the CCN, which is used for exchanges within the EU.
Based on these findings it was concluded that Latvia is fully meeting expectations in relation to agreeing and using appropriate transmission methods with each of its partners. Latvia 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 Latvia’s exchange partners did not raise any concerns with respect to timeliness of the exchanges by Latvia and therefore with respect to Latvia’s implementation of this requirement.
Based on these findings it was concluded that Latvia is fully meeting expectations in relation to exchanging the information in a timely manner. Latvia 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 Latvia’s exchange partners did not raise any concerns with respect to Latvia use of the agreed transmission methods and therefore with Latvia’s implementation of this requirement.
Based on these findings it was concluded that Latvia is fully meeting expectations in relation to sending the information in accordance with the agreed transmission methods and encryption standards. Latvia 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:
19 exchange partners highlighted delays in the sending of status messages by Latvia, representing 18% of its partners. This represents a relatively high proportion of partners and has not improved over time. It was noted that Latvia is engaging with its partners to ensure that status messages are sent in accordance with the requirements and most of these issues have already been resolved.
Based on these findings it was concluded that, overall, Latvia 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 timeliness of status messages. Latvia is encouraged to continue to ensure the ongoing effectiveness of its implementation, including in relation to the area highlighted.
Recommendations:
Latvia 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:
Latvia 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 Latvia’s exchange partners and therefore with respect to Latvia’s implementation of these requirements.
Based on these findings it was concluded that Latvia appears to be meeting expectations in relation to responding to notifications from exchange partners and the sending of corrected, amended, or additional information. Latvia is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.