Bermuda CRS: CITA Steps Up Supervision And Information Requests

Key takeaways

• CITA is increasing its scrutiny of compliance with Bermuda’s Common Reporting Standard (CRS), including through independent compliance reviews and requests for information about the CRS status of Bermuda entities.

• A request about an entity’s CRS status can require a detailed, fact-specific analysis. The correct result may depend on the entity’s activities, income, management arrangements, and other factual background in the period under review. Bermuda entities should review their CRS status remains correct and not assume that an existing portal registration or historic filing position does not need to be updated. 

• Not all entities have obligations under the CRS. Depending on the facts, an entity may be outside the definition of a Financial Institution, may be a Non-Reporting Financial Institution, or may have no Financial Accounts or reporting obligations. Separate account-level exclusions and thresholds may also apply.