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A CRS Compliance Program for Fiduciaries (Bermudian Edition)
The Bermudian Ministry of Finance mandates that Bermudian Financial Institutions (FIs) develop policies and procedures for CRS due diligence and reporting obligations. Pursuant to the requirements in the Bermudian CRS legislation and other sources of applicable guidance, this document sets out a CRS Compliance Program for fiduciaries connected to Bermudian private wealth management structures. It is, however, readily adaptable to other jurisdictions and types of FIs.
Per Bermudian Law, Bermudian Financial Institutions (FIs) must establish and maintain policies and procedures setting forth the methods by which financial account due diligence and reporting obligations are fulfilled. Per the Bermudian CRS Guidance Notes, these policies and procedures should be written.
This document sets out a CRS Compliance Program for fiduciaries connected to Bermudian private wealth management structures and is designed to satisfy the requirements in the Bermudian legislation and accompanying CRS Guidance Notes.
While this document is Bermudian-specific, it can also be adapted to meet the requirements for Compliance Manuals for other jurisdictions.
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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.
For purposes of enforcement, the Ministry of Finance is mandated to periodically verify compliance by Bermudian Reporting FIs and authorized, therefore, to demand further information and documentation from Bermudian entities, as needed.
Non-compliance with duties related to the implementation or enforcement of CRS is either a criminal offence punishable by a summary fine of up to USD 10,000, six (6) months in prison or both; or subject to civil penalties of varying amounts.