On January 1, 2021 the new revisions of the Swiss AEOI Act and the Swiss AEOI Ordinance entered into force. The revision of the FTA AEOI Guidance and the FAQ by the AEOI Qualification Committee followed shortly afterwards.
In our newsletter "Upcoming revision of the Swiss AEOI legislation" we informed on the most important changes enacted by the revision. With the current newsletter, we would like to remind all Swiss FIs to ensure that the changes enacted by the revision are adequately implemented:
If you performed a relationship manager inquiry for pre-existing account holders with an account balance or value over CHF 1’000’000 or treated dormant accounts with an account balance or value below CHF 1’000 as exempt accounts, please make sure to apply U.S. dollars instead of Swiss francs for the purpose of calculating account balances and values when applying these thresholds.
Make sure to obtain new self-certifications before March 31, 2021, if you maintain accounts for the following categories of the account holders:
Condominium and co-owners associations with the AEOI classification “nonreporting FI”.
Accounts that were treated as exempt accounts because they were subject to such a treatment in the countries that they were resident in.
Low-value accounts subject to the residence address test for which the address of the account holder was obtained with a form obtained for KYC/AML-purposes. For such accounts, it is also permissible to obtain documentary evidence instead of a self-certification.
Ensure that all accounts have a self-certification on file at the moment of the account opening. The exception can be made for the entity accounts for which it is possible to determine based on the publicly available information that they are not reportable for AEOI purposes.
Apart from the new rules regarding the application of thresholds, the changes did not have any significant direct impact to the AEOI reporting. In one of our next releases, we will inform you on the AEOI reporting requirements.