A CRS Compliance Program for Fiduciaries (Cayman Edition)

USD $2,000.00

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. 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 connected to Cayman private wealth management structures. It is, however, readily adaptable to other jurisdictions and types of FIs. 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.

Description

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.

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.

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.