Rating: On Track
Saint Kitts and Nevis’ 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 – 2.7) and providing corrections, amendments or additions to the information (SR 2.9). The requirements in relation to the receipt of the information (SR 2.8) have not been assessed as Saint Kitts and Nevis exchanges information non-reciprocally, so does not receive information. Saint Kitts and Nevis 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 Saint Kitts and Nevis’ exchange partners did not raise any specific concerns with respect to their ability to process the information received from Saint Kitts and Nevis and therefore with respect to Saint Kitts and Nevis’ implementation of these requirements. More generally, one of Saint Kitts and Nevis’ exchange partners reported rejecting more than 50% of files received, due to the technical requirements not being met. This is a relatively low amount when compared to other jurisdictions. It was noted that Saint Kitts and Nevis has still not yet addressed the issue.
Based on these findings it was concluded that, overall, Saint Kitts and Nevis 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 ensuring that correct files are sent to all exchange partners. Saint Kitts and Nevis is encouraged to continue its implementation process accordingly, including by addressing the recommendation made.
Recommendations:
Saint Kitts and Nevis should continue to engage with its exchange partner to address the issue 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, Saint Kitts and Nevis linked to the CTS.
Based on these findings it was concluded that Saint Kitts and Nevis is fully meeting expectations in relation to agreeing and using appropriate transmission methods with each of its partners. Saint Kitts and Nevis 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 Saint Kitts and Nevis. This represents a relatively high proportion of exchange partners. Furthermore, Saint Kitts and Nevis has still not yet sent some of the information due to be exchanged in 2021.
Based on these findings it was concluded that, overall, Saint Kitts and Nevis is meeting expectations in relation exchanging information in a timely manner. It was also noted that there is room for improvement with respect to ensuring that information is exchange with all of its partners in a timely manner. Saint Kitts and Nevis is encouraged to continue to ensure the ongoing effectiveness of its implementation, including by addressing the recommendation made.
Recommendations:
Saint Kitts and Nevis should ensure it sends information to all of its 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 Saint Kitts and Nevis’ exchange partners did not raise any concerns with respect to Saint Kitts and Nevis’ use of the agreed transmission methods and therefore with Saint Kitts and Nevis’ implementation of this requirement.
Based on these findings it was concluded that Saint Kitts and Nevis is fully meeting expectations in relation to sending the information in accordance with the agreed transmission methods and encryption standards. Saint Kitts and Nevis 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 Saint Kitts and Nevis 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:
Saint Kitts and Nevis 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 Saint Kitts and Nevis exchange partners and therefore with respect to Saint Kitts and Nevis’ implementation of these requirements.
Based on these findings it was concluded that Saint Kitts and Nevis appears to be meeting expectations in relation to responding to notifications from exchange partners and the sending of corrected, amended or additional information. Saint Kitts and Nevis is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.