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A CRS Compliance Program for Fiduciaries (Cayman Edition)
Updated to include Cayman CRS Compliance Form requirements
Pursuant to the requirements in the Cayman CRS legislation and other sources of applicable guidance, this document sets out a CRS Compliance Program for fiduciaries managing Cayman private wealth management structures. It is, however, readily adaptable to other jurisdictions and types of FIs.
Cayman Financial Institutions (FIs), including trustees on behalf of Trustee-documented Trusts, must “establish and maintain policies and procedures” setting forth the methods by which financial account due diligence and reporting obligations are fulfilled.
This document sets out a CRS Compliance Program for fiduciaries connected to Cayman private wealth management structures and is designed to satisfy the requirements in the Cayman legislation and accompanying CRS Guidance Notes.
While this document is Cayman-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 the entity’s CRS compliance
- Entity classification, delegation and registration
- Identification, due diligence and monitoring of CRS Account Holders and Controlling Persons
Non-compliance with duties related to the implementation or enforcement of CRS – including the failure to establish a written compliance program – is a criminal offence punishable by a fine of up to USD 50,000.
Managing personnel, including directors and officers for companies, general partners for funds and trustees for trusts, are personally liable for non-compliance of Cayman FIs they manage.