Cayman Islands & BVI AEOI Update: Q4 2017

As clients will be aware, the Cayman Islands and the British Virgin Islands ("BVI") have legislation in place which brought the OECD's Common Reporting Standard ("CRS") into law with effect from 1 January 2016. Clients with entities operating in either the Cayman Islands or BVI and which constitute Reporting Financial Institutions ("RFIs") for CRS purposes should note the following:

Deadlines

Any RFI which had preexisting accounts as at 31 December 2015 is under an obligation to conduct due diligence on those preexisting accounts. The deadline for Preexisting High Value Individual Accounts was 31 December 2016. The deadline for all other accounts, i.e. Preexisting Lower Value Individual Accounts and Preexisting Entity Accounts, is 31 December 2017. For the purposes of this deadline, a Preexisting Lower Value Individual Account is one that had a balance or value that does not exceed US$1 million as of 31 December 2015, and a Preexisting Entity Account is one that