Are you prepared for the upcoming CRS Compliance Form filing deadline of 15 September 2022?

As you may be aware, 15 September 2022 is the deadline for filing the CRS Compliance Form with the Cayman Department for International Tax Cooperation (DITC).

The CRS Compliance Form is a mandatory form that is to be filed annually by all Cayman Islands Financial Institutions (Cayman FIs), and is in addition to the Cayman FI's CRS Return submitted on 31 July of each year for the same reporting period. 

The CRS Compliance Form requires a Cayman FI to make certain certifications regarding its overall compliance with its CRS obligations, including confirmations as to whether it has registered with the Cayman Islands Monetary Authority (CIMA), that it maintains written CRS compliance policies and procedures, and that it has collected the necessary self-certification forms to support its CRS reporting.

The DITC has stated that it will consider appropriate compliance and enforcement action where misclassification and non-compliance (including, for example, failure to register with the DITC, failure to maintain and review its written CRS compliance policies and procedures and failure to collect self-certification forms and maintain adequate records in respect of its CRS filings) is discovered, including administrative penalties or fines. The DITC's CRS enforcement guidelines are available here and the general CRS guidelines for Cayman FIs are available here.

For more information on the CRS enforcement guidelines, read Ogier's recent Cayman Islands funds and regulatory update for Q1 2022.

How can Ogier Global help?

Where Ogier Global has been engaged to provide FATCA/CRS compliance services, the CRS Compliance Form will be completed and filed with the DITC ahead of the deadline.

If you require assistance with completing and submitting your CRS Compliance Form prior to the deadline, please reach out to a member of Ogier Global's dedicated AEOI (FATCA / CRS) Compliance team below.

How can Ogier help?

Ogier's Regulatory team routinely advises on AEOI (FATCA / CRS) compliance and enforcement matters in the Cayman Islands.

Should you require legal advice in relation to any such matters, please reach out to Martin Byers or your usual Ogier contact.