Rating: Non-Compliant
Saint Vincent and the Grenadines’ implementation of the AEOI Standard is non-compliant with respect to exchanging the information effectively in practice and in a timely manner. More specifically, while Saint Vincent and the Grenadines is meeting expectations with respect correctly putting transmission mechanisms in place (SR 2.5), there are fundamental issues with respect to Saint Vincent and the Grenadines transmitting the information in a timely manner (SR 2.6). Furthermore, due to the delays in exchanges, it was not possible to assess Saint Vincent and the Grenadines' implementation of the requirements in relation to sorting, preparing and validating the information (SR 2.4) and the correct transmission of the information in practice (SR 2.7). The requirements in relation to the receipt of the information (SR 2.8) have not been assessed as Saint Vincent and the Grenadines exchanges information non-reciprocally, so does not receive information. Saint Vincent and the Grenadines 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:
No feedback has been received from Saint Vincent and the Grenadines’ exchange partners with respect to their ability to process the information received from Saint Vincent and the Grenadines and therefore with respect to Saint Vincent and the Grenadines’ implementation of these requirements. This reflects the fact that Saint Vincent and the Grenadines did not carry out the exchanges that were due to take place in 2020 and 2021 due to technical problems.
It has therefore not been possible to review Saint Vincent and the Grenadines in relation to SR 2.4.
Recommendations:
No assessment possible.
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 Vincent and the Grenadines linked to the CTS.
Based on these findings it was concluded that Saint Vincent and the Grenadines is fully meeting expectations in relation to agreeing and using appropriate transmission methods with each of its partners. Saint Vincent and the Grenadines 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:
Whilst Saint Vincent and the Grenadines was able to exchange information in 2018 and 2019, it has subsequently faced significant technical issues and has consequently not yet carried out the exchanges that were due to take place in 2020 and 2021.
Based on these findings it was concluded that Saint Vincent and the Grenadines is not meeting expectations in relation to exchanging the information in a timely manner. More specifically, fundamental issues have been identified, including with respect to the technical capacity to ensure the exchanges with all partners in a timely manner. Saint Vincent and the Grenadines should continue its implementation process to ensure its effectiveness, including by addressing the recommendations made.
Recommendations:
Saint Vincent and the Grenadines should ensure that 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:
No feedback has been received from Saint Vincent and the Grenadines’ exchange partners with respect to Saint Vincent and the Grenadines’ use of the agreed transmission methods and therefore with Saint Vincent and the Grenadines’ implementation of this requirement, as Saint Vincent and the Grenadines did not carry out exchanges in 2020 and 2021 due to technical problems.
It has therefore not been possible to review Saint Vincent and the Grenadines in relation to SR 2.7.
Recommendations:
No assessment possible.
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 Vincent and the Grenadines exchanges information on a non-reciprocal basis and does not 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:
Given the technical difficulties that Saint Vincent and the Grenadines has experienced, it is unclear that corrected, amended or additional information will be provided in a timely manner. Nevertheless, it has not been tested and no such concerns were raised by Saint Vincent and the Grenadines’ exchange partners.
Based on these findings and as no particular issues were identified, it was concluded that Saint Vincent and the Grenadines appears to be meeting expectations in relation to responding to notifications from exchange partners and the sending of corrected, amended or additional information. Saint Vincent and the Grenadines is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.