A CRS Compliance Program for Fiduciaries (Bahamian Edition)

USD 1,600.00

The Bahamian Ministry of Finance mandates that Bahamian Financial Institutions (FIs) develop written policies and procedures for CRS due diligence and reporting obligations . Pursuant to the requirements in the Bahamian CRS legislation and other sources of applicable guidance, this document sets out a CRS Compliance Program for fiduciaries connected to Bahamian private wealth management structures.  It is, however, readily adaptable to other jurisdictions and types of FIs.

Description

Bahamian FIs must prepare and maintain written documentation setting forth the methods by which the due diligence and reporting obligations are fulfilled.

Pursuant to the requirements in the Bahamian CRS legislation and other sources of applicable guidance, this document sets out a CRS Compliance Program for fiduciaries connected to Bahamian private wealth management structures.

It is, however, readily adaptable to other jurisdictions and types of FIs.

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This resource covers:

  • Determination of the applicable jurisdiction and the rules governing an entity’s CRS status;
  • Entity classification, registration and delegation;
  • Identification, due diligence and monitoring of CRS Account Holders and Controlling Persons; and
  • Preparation, registration and submission of CRS account reporting.

Caution

Failure to comply with this obligation or any duty related to the implementation of CRS is an offense punishable by a fine of up to USD 25,000 per offence.

For purposes of enforcement, the Ministry of Finance is mandated to periodically verify compliance by Bahamian entities and authorized to demand further information and documentation from Bahamian entities and Persons connected to them and impose administrative penalties of up to USD 300,000 for non-compliance.