IEIM402880 - Due Diligence: Pre-Existing Individual Accounts: Lower Value Accounts: Curing Indicia

Due Diligence: Pre-Existing Individual Accounts: Lower Value Accounts: Curing Indicia

»Ê¹ÚÌåÓýappre may be occasions when the electronic record search gives indications of residence in a Reportable Jurisdiction [see IEIM402780] that the Financial Institution considers may be incorrect. In such circumstances the Financial Institution may take steps to ‘cureâ€� the information before treating the Account Holder as a Reportable Person.

Where the Financial Institution holds information about the Account Holder that includes any of

  1. a current mailing address in a Reportable Jurisdiction,
  2. one or more telephone numbers in a Reportable Jurisdiction (and no telephone number in the UK),
  3. standing instructions [see IEIM402847], other than with respect to Depository Accounts , to transfer funds to an account maintained in a Reportable Jurisdiction, or
  4. a currently effective power of attorney or signatory authority granted to a person with an address in a Reportable Jurisdiction, then

the Financial Institution may obtain a self-certification from the Account Holder to ‘cureâ€� the information by establishing the jurisdiction of residence. »Ê¹ÚÌåÓýapp Financial Institution can rely on self-certifications it has previously reviewed and maintained a record of, but in either case the self-certification must be supported by documentary evidence [see IEIM403180]. If the self-certification supported by documentary evidence establishes that the Account Holder is not a Reportable Person then the Financial Institution is not required to treat the Account Holder as resident in a Reportable Jurisdiction.

»Ê¹ÚÌåÓýapp self-certification obtained as part of the curing procedure does not need to contain an express confirmation that an Account Holder is not resident in a particular jurisdiction. Provided the self-certification positively identifies the jurisdictions where the Account Holder is resident it can be taken that the Account Holder is not resident in any other jurisdiction.

Where a Financial Institution has contacted an Account Holder for a self-certification but the Account Holder has not responded, the account should be treated as reportable 90 days after initiating contact. »Ê¹ÚÌåÓýapp 90 day period is to allow the Account Holder sufficient time to respond to the request for information.

»Ê¹ÚÌåÓýapp information in 4. above may arise in circumstances where the Account Holder cannot provide a self-certification. In such a case the Financial Institution may rely on documentary evidence that establishes the Account Holder’s non-reportable status.