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<h1>Guidance CRS/FATCA due-diligence limits reliance on PMLA data; trusts' controlling persons include settlors, trustees, beneficiaries; passive NFEs accept self-certification</h1> Circular clarifies CRS/FATCA due-diligence: reporting financial institutions may rely on information collected under PMLA rules only to the extent those rules conform to the FATF 2012 recommendations. For trusts, the definition of 'controlling person' follows the CRS explanation, so all settlors, trustees, beneficiaries or classes of beneficiaries (regardless of interest size) and any natural person exercising ultimate effective control must be treated as controlling persons for due-diligence and reporting. For new-entity accounts of passive NFEs, institutions may rely solely on self-certification from the account holder or controlling person to determine reportability.