Based on these findings it was concluded that, overall, Ghana 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 working with its exchange partners to address the issues raised. Ghana is therefore encouraged to continue its implementation process accordingly, including in relation to the area highlighted.
Recommendations:
Ghana 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, Ghana linked to the Common Transmission System.
Based on these findings it was concluded that Ghana is fully meeting expectations in relation to agreeing and using appropriate transmission methods with each of its partners. Ghana 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 Ghana’s exchange partners did not raise any concerns with respect to timeliness of the exchanges by Ghana and therefore with respect to Ghana’s implementation of this requirement.
Based on these findings it was concluded that Ghana is fully meeting expectations in relation to exchanging the information in a timely manner. Ghana 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 Ghana’s exchange partners did not raise any concerns with respect to Ghana’s use of the agreed transmission methods and therefore with Ghana’s implementation of this requirement.
Based on these findings it was concluded that Ghana is fully meeting expectations in relation to sending the information in accordance with the agreed transmission methods and encryption standards. Ghana 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:
Three exchange partners highlighted delays in the sending of status messages by Ghana, representing 4% of its partners. This represents a relatively high proportion of partners. It was noted that Ghana appears to be successfully addressing the issues to ensure that status messages are sent in accordance with the requirements.
Based on these findings it was concluded that, overall, Ghana is meeting expectations in relation to the receipt of the information. It was also noted that there is room for improvement with respect to sending status messages to all of its exchange partners in a timely manner. Ghana is encouraged to continue to ensure the ongoing effectiveness of its implementation, including in relation to the area highlighted.
Recommendations:
Ghana 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:
While it is unclear whether Ghana’s approach will ensure that corrected, amended or additional information is provided in a timely manner, it has not been tested and no such concerns were raised by Ghana’s exchange partners and therefore with respect to Ghana’s implementation of these requirements.
Based on these findings it was concluded that Ghana appears to be meeting expectations in relation to responding to notifications from exchange partners and the sending of corrected, amended or additional information. Ghana is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.