AEOI Obligations - Guide For Financial Institutions

Introduction

Pursuant to the Regulations¹ adopted by the Cayman Islands to implement the AEOI regimes, each Cayman Islands entity that is a Reporting Financial Institution (a "FI") is required to:

1. register with the United States Internal Revenue Service (the "IRS") to obtain a Global Intermediary Identification Number (a "GIIN") (US Regulations only);
2. notify the Cayman Islands Department for International Tax Cooperation (the "DITC") that the FI will be subject to reporting obligations under one or more sets of the Regulations;
3. implement a due diligence programme to facilitate the identification of any reportable account holders; and
4. report on any such accounts identified by the requisite reporting deadline.