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.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.