A CRS Compliance Program for Fiduciaries (BVI Edition)

USD $1,200.00

The International Tax Authority (ITA) of the British Virgin Islands (BVI) mandates that BVI Reporting Financial Institutions (FIs) and trustees of BVI Trustee-documented Trusts must adopt written policies and procedures for their CRS Compliance Program (or risk fines of up to USD 100,000). Pursuant to the requirements in the BVI CRS legislation and other sources of applicable guidance, this document sets out a CRS Compliance Program for fiduciaries connected to BVI private wealth management structures.  It is, however, readily adaptable to other jurisdictions and types of FIs.

Description

The International Tax Authority (ITA) of the British Virgin Islands (BVI) mandates that BVI Reporting Financial Institutions (FIs) and trustees of BVI Trustee-documented Trusts (TDTs) must adopt written policies and procedures for their CRS Compliance Program by 31 March 2019.

Specifically, pursuant to Section 27(1) of BVI’s CRS legislation, BVI FIs must “establish, implement and maintain written policies and procedures” to comply with the legislation.

Article 3 of the BVI CRS Guidance Notes (19 February 2019 version) further confirms that this obligation applies to BVI Reporting FIs and trustees on behalf of BVI TDTs.

Failure of any BVI FIs to comply with this obligation is a criminal offence and is punishable by a fine of up to USD 100,000.

This document sets out a CRS Compliance Program for fiduciaries connected to BVI private wealth management structures and is designed to satisfy the requirements in the BVI legislation and accompanying CRS Guidance Notes.

While this document is BVI-specific, it can also be adapted to meet the requirements for Compliance Manuals for other jurisdictions.