Rating: On Track
Anguilla’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 (SRs 2.5 - 2.7) and providing corrections, amendments or additions to the information (SR 2.9), although improvements are needed to exchange the information in a timely manner. The requirements in relation to the receipt of the information (SR 2.8) have not been assessed as Anguilla exchanges information non-reciprocally, so does not receive information. Anguilla has shown improvement over time and 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:
Two exchange partners highlighted particular issues with respect to preparation and format of the information sent by Anguilla (representing 3% of its partners). These generally related to verifying and sorting data. More generally, two (or 3%) of Anguilla’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 Anguilla has still not yet addressed all of the issues.
Based on these findings it was concluded that, overall, Anguilla 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 issues raised by the exchange partners. Anguilla is therefore encouraged to continue its implementation process accordingly, including in relation to the area highlighted.
Recommendations:
Anguilla 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, Anguilla linked to the CTS.
Based on these findings it was concluded that Anguilla is fully meeting expectations in relation to agreeing and using appropriate transmission methods with each of its partners. Anguilla 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 Anguilla (representing 8% of its partners). This represents a relatively high proportion of exchange partners, although it has improved over time. Furthermore, two partners stated that the information has still not been received.
Based on these findings it was concluded that Anguilla 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 exchanges.
Recommendations:
Anguilla 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 Anguilla’s exchange partners did not raise any concerns with respect to Anguilla’s use of the agreed transmission methods and therefore with Anguilla’s implementation of this requirement.
Based on these findings it was concluded that Anguilla is fully meeting expectations in relation to sending the information in accordance with the agreed transmission methods and encryption standards. Anguilla 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.
It should be noted that, as Anguilla exchanges information on a non-reciprocal basis and does not therefore receive information, it is not required to have in place systems to receive the information and provide status messages. SR 2.8 has therefore not been assessed in this case.
Findings:
Not applicable.
Recommendations:
Not applicable.
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:
Feedback from Anguilla’s exchange partners did not raise any concerns with respect to Anguilla’s response to notifications or provision of corrected, amended or additional information and therefore with respect to Anguilla’s implementation of these requirements.
Based on these findings it was concluded that Anguilla appears to be fully meeting expectations in relation to responding to notifications from exchange partners and the sending of corrected, amended or additional information. Anguilla is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.