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(1) These Regulations may be cited as the Tax Information Authority (International Tax Compliance) (Common Reporting Standard) (Amendment) Regulations, 2025. (2) With the exception of regulations 5 and 6, these Regulations come into force on 1st January, 2026. (3) Regulations 5 and 6 come into force on 1st January, 2027. Regulation 2 Tax Information Authority ( International Tax Compliance) (Common Reporting Standard) (Amendment) Regulations, 2025 SL 50 of 2025 2. Amendment of regulation 2 of the Tax Information Authority (International Tax Compliance) (Common Reporting Standard) Regulations (2021 Revision) - definitions 2. The Tax Information Authority (International Tax Compliance) (Common Reporting Standard) Regulations (2021 Revision), in these Regulations referred to as the \u201cprincipal Regulations\u201d, are amended in regulation 2(1) as follows \u2014 (a) by inserting, in the appropriate alphabetical sequence, the following definitions \u2014 \u201c \u201caccurate\u201d, in relation to information provided, means the information is correct and reliable; \u201cadequate\u201d, in relation to the information provided under a regulation, means that it contains all of the details specified in that regulation; \u201cchange of circumstances\u201d includes \u2014 (a) a change in the information relevant to the status of an Account Holder or Controlling Person; or (b) a change that otherwise conflicts with the status of an Account Holder or Controlling Person; \u201ccompliance form\u201d means a compliance form required under regulation 9(2); \u201ccurrent\u201d, in relation to the information provided, means the information is as up to date as is reasonably practicable and incorporates any information relating to a change of circumstance that occurred within the period to which the return, declaration, or any other information relates; \u201cgovernment entity\u201d includes a ministry, or portfolio of the Government, the Cabinet Office, the Office of the Director of Public Prosecutions, the Office of the Ombudsman, the Audit Office, the Parliament, a statutory body established under the laws of the Islands, and a public authority; \u201cpublic authority\u201d means a public authority as defined under section 2 of the Public Authorities Act (2020 Revision); \u201cself-certification\u201d means information, by whatever name called, that performs or purports to perform a purpose of a self-certification under the Common Reporting Standard;\u201d; (b) in the definition of the words \u201cbreach notice\u201d by deleting the words \u201cin regulation 28(1)(a)\u201d and substituting the words \u201cin regulation 29\u201d; (c) in paragraph (a) of the definition of the words \u201cCayman Financial Institution\u201d by deleting the word \u201cand\u201d and substituting the word \u201cor\u201d; Tax Information Authority ( International Tax Compliance) (Common Reporting Standard) (Amendment) Regulations, 2025 Regulation 3 SL 50 of 2025 (d) by deleting the definition of the words \u201cCommon Reporting Standard\u201d and substituting the following definition \u2014 \u201c \u201cCommon Reporting Standard\u201d means the standard for automatic exchange of financial account information developed by the Organisation for Economic Co-Operation and Development, set out in the Schedule;\u201d; (e) by deleting the definition of the word \u201ccontravention\u201d and substituting the following definition \u2014 \u201c \u201ccontravention\u201d, in relation to a provision pertaining to an offence or a penalty, means the act or omission that constituted the offence and to which the penalty relates;\u201d; (f) by deleting the definition of the word \u201cgive\u201d and substituting the following definition \u2014 \u201c \u201cgive\u201d, in relation to a notice or information, includes to deliver, provide, send, transmit or make the notice or information, as applicable;\u201d; (g) by deleting the respective definitions of the words \u201cinaccurate\u201d and \u201cinterest\u201d; (h) in the definition of the words \u201cpenalty notice\u201d by deleting the words \u201cin regulation 28(1)(c)\u201d and substituting the words \u201cin regulation 31\u201d; (i) in paragraph (a) of the definition of the words \u201cresident in the Islands\u201d by inserting after the word \u201cincorporated\u201d the words \u201c, registered\u201d; (j) by deleting the definition of the word \u201creturn\u201d and substituting the following definition \u2014 \u201c \u201creturn\u201d (other than in the Schedule) means a return required under regulation 9(1)(a) or a nil return under regulation 9(1)(b);\u201d; and (k) by deleting the definition of the word \u201cstayed\u201d and substituting the following definition \u2014 \u201c \u201cstayed\u201d, in relation to a penalty, means that the penalty cannot be enforced \u2014 (a) because of the operation of regulation 30(1); or (b) in accordance with regulation 33(1).\u201d. 3. Repeal and substitution of regulation 7 - required policies and procedures for Cayman Reporting Financial Institutions 3. The principal Regulations are amended by repealing regulation 7 and substituting the following regulation \u2014 Regulation 3 Tax Information Authority ( International Tax Compliance) (Common Reporting Standard) (Amendment) Regulations, 2025 SL 50 of 2025 \u201cRequired due diligence for Cayman Financial Institutions\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_7\", \"num\": \"7.\", \"text\": \"(1) Each Cayman Financial Institution shall establish, implement, maintain and comply with written policies and procedures that comply with the reporting and due diligence requirements set out in Sections II to VII of the Common Reporting Standard. (2) Without limiting paragraph (1), the policies and procedures shall \u2014 (a) identify each jurisdiction in which an Account Holder or a Controlling Person is resident for tax purposes; (b) apply the due diligence procedures set out in Sections II to VII of the Common Reporting Standard; (c) ensure that valid self-certifications, in accordance with paragraph (4) are collected; and (d) ensure that any information obtained in accordance with this Part, or a record of the steps taken to comply with this Part, in respect of a Financial Account is kept for at least six years from the end of the year to which the information relates or during which the steps were taken. (3) Subject to the paragraph headed \u201cAbis. Temporary lack of SelfCertification.\u201d set out in Section VII of the Common Reporting Standard, each Cayman Financial Institution shall collect a valid selfcertification, in accordance with paragraph (4), for new accounts, on or before the date a Financial Account is opened. (4) In order for a self-certification to be valid it shall include the following current information with respect to \u2014 (a) Individual Account Holders and Controlling Persons \u2014 (i) name; (ii) permanent residence address; (iii) the jurisdiction(s) of residence for tax purposes; (iv) TIN or functional equivalent for each Reportable Jurisdiction; (v) date of birth; (vi) place of birth; (vii) signature or attestation of the form; and (viii) date of signature or attestation; and (b) Entity Account Holders \u2014 (i) name; (ii) address; (iii) the jurisdiction(s) of residence for tax purposes; Tax Information Authority ( International Tax Compliance) (Common Reporting Standard) (Amendment) Regulations, 2025 Regulation 4 SL 50 of 2025 (iv) TIN or functional equivalent for each Reportable Jurisdiction; (v) the type of Reporting Financial Institution, Non-Reporting Financial Institution or Non-Financial Entity, the entity is; (vi) signature or attestation of the form; and (vii) date of signature or attestation. (5) In this regulation, \u201cresident for tax purposes\u201d means resident for income tax or corporation tax purposes or for the purpose of any tax imposed by the law of the jurisdiction that is of a similar character to either of those taxes; and \u201cresidence for tax purposes\u201d is to be construed accordingly.\u201d. 4. Amendment of regulation 8 - obligation of Cayman Financial Institutions to notify certain information 4. The principal Regulations are amended in regulation 8 as follows \u2014 (a) by repealing paragraphs (1) and (2) and substituting the following paragraphs \u2014 \u201c(1) Each Cayman Financial Institution, other than an exempted body, shall submit to the Authority \u2014 (a) subject to paragraph (3A), a registration form stating the required information about the institution on or before the next 31st January, if the entity became a Financial Institution in the previous calendar year; and (b) if any of the required information so notified changes, a notice stating details of the change (a \u201cchange form\u201d), and any change form shall be submitted within thirty days after the change occurring. (2) A registration form or change form shall be adequate, accurate and current and shall be given through the electronic portal in the form and manner specified by the Authority.\u201d; (b) in paragraph (3) by deleting the words \u201cchange notice\u201d wherever they appear and substituting the words \u201cchange form\u201d; (c) by inserting after paragraph (3) the following paragraphs \u2014 \u201c(3A)A Cayman Financial Institution, other than an exempted body that became a Financial Institution in 2025, shall submit the registration form stating the required information about the institution on or before 30th April, 2026. Regulation 4 Tax Information Authority ( International Tax Compliance) (Common Reporting Standard) (Amendment) Regulations, 2025 SL 50 of 2025 (3B) Where, prior to the commencement of the Tax Information Authority (International Tax Compliance) (Common Reporting Standard) (Amendment) Regulations, 2025, a Cayman Financial Institution \u2014 (a) was registered with the Authority; and (b) has not notified the Authority of a person in the Islands authorised to act as its principal point of contact for compliance with this Part, the Cayman Financial Institution shall, on or before 31st January 2027, submit a change form to the Authority notifying the Authority of the person in the Islands whom it has authorised to act as its principal point of contact for compliance with this Part.\u201d; and (d) by repealing paragraph (4) and substituting the following paragraph \u2014 \u201c(4) In this regulation \u2014 \u201cexempted body\u201d means \u2014 (a) the Cayman Islands Monetary Authority under section 5(1) of the Monetary Authority Act (2020 Revision) (\u201cCIMA\u201d); (b) a government entity; or (c) a Pension Fund of CIMA or a government entity; and \u201crequired information\u201d, for a Cayman Financial Institution, means \u2014 (a) the institution\u2019s name and any number given to it by the General Registry, Cayman Islands Monetary Authority, or other regulatory or supervisory body; (b) whether the institution is a Cayman Reporting Financial Institution or a Non-Reporting Financial Institution; (c) if the institution is a Cayman Reporting Financial Institution, a correct statement of its classification under Section VIII(A) of the Common Reporting Standard; (d) if the institution is a Non-Reporting Financial Institution, a correct statement of its classification under Section VIII(B) of the Common Reporting Standard; (e) the date the entity became a Financial Institution; and (f) the full name, address, business entity, position and contact details (including an electronic address) of \u2014 (i) a person, in the Islands, that the institution has authorised to be its principal point of contact for compliance with this Part; and Tax Information Authority ( International Tax Compliance) (Common Reporting Standard) (Amendment) Regulations, 2025 Regulation 5 SL 50 of 2025 (ii) except in circumstances specified by the Authority, another person that the institution has authorised to give change forms for its principal point of contact.\u201d.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_5\", \"num\": \"5.\", \"text\": \"Repeal and substitution of regulation 9 - obligation to make a return 5. The principal Regulations are amended by repealing regulation 9 and substituting the following regulation \u2014 \u201cObligation to make a return and a compliance form\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_9\", \"num\": \"9.\", \"text\": \"(1) Each Cayman Financial Institution, shall in each calendar year \u2014 (a) make a return to the Authority for each Reportable Account the institution maintained during the year in accordance with the requirements specified in Section I of the Common Reporting Standard; or (b) if the institution did not maintain any Reportable Account in a Reportable Jurisdiction during the year, make a nil return for that Reportable Jurisdiction, on or before the 30th of June of the year following the calendar year to which the return relates, together with a declaration made by the Cayman Financial Institution that states that the information provided in the return is adequate, accurate and current. (2) Subsequent to the filings required under paragraph (1), a Cayman Financial Institution shall, for each calendar year, make and submit to the Authority a compliance form on or before the 30th of June of the year following the year to which the compliance form relates, together with a declaration made by the Cayman Financial Institution that states that the information provided in the compliance form is adequate, accurate and current. (3) A Cayman Financial Institution shall provide to the Authority information reasonably required by the Authority to ensure effective implementation of, and compliance with, the reporting and due diligence procedures in accordance with the Common Reporting Standard. (4) For the purposes of the information required to be reported under the Common Reporting Standard \u2014 (a) a reference to the balance or value of an account includes a nil balance or value; and (b) a reference to paying an amount includes crediting an amount. (5) The information provided under this regulation shall be adequate, accurate and current. Regulation 6 Tax Information Authority ( International Tax Compliance) (Common Reporting Standard) (Amendment) Regulations, 2025 SL 50 of 2025 (6) The Authority may require corrections to the return and compliance form by notice issued to the relevant Cayman Financial Institution and shall, in the notice, specify the date by which the corrections shall be made.\u201d.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_6\", \"num\": \"6.\", \"text\": \"Repeal and substitution of regulation 10 - requirements for making returns 6. The principal Regulations are amended by repealing regulation 10 and substituting the following regulation \u2014 \u201cRequirements for making a return or a compliance form\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_10\", \"num\": \"10.\", \"text\": \"(1) Returns, compliance forms, and declarations shall be submitted through the electronic portal in the form and manner specified by the Authority. (2) The Authority shall notify Cayman Financial Institutions of the electronic portal and its usage by \u2014 (a) a post on an official website, for their information generally; or (b) a notice given to any particular Cayman Financial Institution in question. (3) Unless the contrary is proved, the Authority shall presume that a return or compliance form accepted by the electronic portal \u2014 (a) has been submitted as required under paragraph (1); or (b) was submitted \u2014 (i) when the return or compliance form was accepted by the electronic portal; (ii) by the person who filed the return or compliance form by using the electronic portal; and (iii) with the authority of the Cayman Financial Institution on whose behalf the return or compliance form purports to have been submitted.\u201d. 7. Repeal and substitution of regulation 12 - Authority\u2019s monitoring function 7. The principal Regulations are amended by repealing regulation 12 and substituting the following regulation \u2014 \u201cAuthority\u2019s monitoring function\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_12\", \"num\": \"12.\", \"text\": \"(1) The Authority may by notice given to an entity, require the entity \u2014 (a) within a time specified by the Authority, to provide to the Authority information, including a copy of a relevant book, document or other record, or of electronically stored information; or Tax Information Authority ( International Tax Compliance) (Common Reporting Standard) (Amendment) Regulations, 2025 Regulation 8 SL 50 of 2025 (b) at a time specified by the Authority, to make available to the Authority for inspection, a book, document or other record, or any electronically stored information, that is in the entity\u2019s possession or under its control, that the Authority reasonably requires to verify the classification of the entity or to decide whether or not information the entity gave the Authority was adequate, accurate and current. (2) If the information that the Authority wants or wants to inspect, is outside of the Islands and the Authority requires the entity to bring the information to the Islands, the Authority shall specify a time that will enable the entity to bring the information to the Islands and the entity shall comply with the requirement of the Authority. (3) A Cayman Financial Institution shall retain for at least six years a book, document or other record, including any information stored by electronic means, that relates to the information required to be reported to the Authority under this Part.\u201d.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_8\", \"num\": \"8.\", \"text\": \"Amendment of regulation 14 - offence pertaining to false self certification 8. The principal Regulations are amended in regulation 14 as follows \u2014 (a) by repealing the regulation heading and substituting the following regulation heading \u2014 \u201cOffence pertaining to false self-certification\u201d; and (b) by repealing paragraph (3) and substituting the following paragraph \u2014 \u201c(3) In this regulation, \u201cmakes\u201d means to sign or otherwise positively affirm.\u201d. 9. Repeal of regulation 16 - inaccurate information offence 9. The principal Regulations are amended by repealing regulation 16. 10. Amendment of regulation 17 - offence pertaining to access to confidential information 10. The principal Regulations are amended in regulation 17 as follows \u2014 (a) by renumbering the regulation as paragraph (1) of regulation 17; (b) in paragraph (1)(a) as renumbered, by deleting the word \u201cmaterially\u201d; and (c) by inserting after paragraph (1) as renumbered, the following paragraph \u2014 \u201c(2) In paragraph (1)(a) \u201cinaccurate\u201d means incomplete, incorrect or unreliable.\u201d. Regulation 11 Tax Information Authority ( International Tax Compliance) (Common Reporting Standard) (Amendment) Regulations, 2025 SL 50 of 2025\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_11\", \"num\": \"11.\", \"text\": \"Amendment of regulation 24 - power to penalise 11. The principal Regulations are amended in regulation 24 by inserting after paragraph (3) the following paragraphs \u2014 \u201c(3A)The Authority shall not impose a continuing penalty where a primary penalty in the amount of fifty thousand dollars is imposed under paragraph (1)(a). (3B) Where the sum of the primary penalty and any continuing penalty imposed is fifty thousand dollars, the Authority shall not impose any additional continuing penalties.\u201d. 12. Amendment of regulation 28 - steps required to impose penalty 12. The principal Regulations are amended in regulation 28 by repealing paragraph (1) and substituting the following paragraphs \u2014 \u201c(1) Subject to paragraph (1A), where the Authority decides to impose a penalty, the Authority shall impose the primary penalty by \u2014 (a) giving the party a breach notice; (b) if regulation 30 applies, complying with that regulation; and (c) giving the party a penalty notice. (1A) In the case of a contravention of regulation 9, the Authority may impose a penalty by giving the party a penalty notice, without first having taken the steps under paragraph (1)(a) or (b).\u201d\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_13\", \"num\": \"13.\", \"text\": \"Amendment of regulation 29 - breach notice for primary penalty 13. The principal Regulations are amended in regulation 29 as follows \u2014 (a) in paragraph (1)(e) by inserting after the word \u201crepresentations\u201d the words \u201ctogether with supporting documentation\u201d; and (b) in paragraph (2) by deleting the word \u201csixty\u201d and substituting the word \u201cthirty\u201d.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_14\", \"num\": \"14.\", \"text\": \"Amendment of regulation 30 - considering representations and deciding primary penalty 14. The principal Regulations are amended in regulation 30 as follows \u2014 (a) in paragraph (1) by inserting after the word \u201crepresentations\u201d the words \u201ctogether with supporting documentation within the period\u201d; and (b) in paragraph (2) by deleting the word \u201cThe\u201d and substituting the words \u201cIn accordance with paragraph (1), the\u201d. Tax Information Authority ( International Tax Compliance) (Common Reporting Standard) (Amendment) Regulations, 2025 Regulation 15 SL 50 of 2025 15. Amendment of regulation 33 - automatic stay on appeal 15. The principal Regulations are amended in regulation 33(1) by deleting the words \u201cor interest\u201d.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_16\", \"num\": \"16.\", \"text\": \"Amendment of regulation 34 - appeal hearing and outcome 16. The principal Regulations are amended in regulation 34 as follows \u2014 (a) in paragraph (3)(b) by deleting the words \u201cand for interest\u201d; and (b) in paragraph (4) by deleting the words \u201cboth the penalty and interest are\u201d and substituting the words \u201cthe penalty is\u201d.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_17\", \"num\": \"17.\", \"text\": \"Repeal of regulation 35 - interest 17. The principal Regulations are amended by repealing regulation 35.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_18\", \"num\": \"18.\", \"text\": \"Amendment of regulation 38 - evidentiary provisions 18. The principal Regulations are amended in regulation 38 as follows \u2014 (a) in paragraph (1) by deleting the words \u201cor interest\u201d; and (b) in paragraph (3) as follows \u2014 (i) in subparagraphs (d) and (f), respectively, by deleting the words \u201cCayman Reporting Financial Institution\u201d and substituting the words \u201cCayman Financial Institution\u201d; and (ii) in subparagraph (j) by deleting the words \u201cor interest\u201d. 19. Amendment of Schedule - Common Standard on Reporting and Due Diligence for Financial Account Information 19. The principal Regulations are amended in the Schedule as follows \u2014 (a) in Section I(A) as follows \u2014 (i) by repealing the words \u201cSubject to paragraphs C through E\u201d and substituting the words \u201cSubject to paragraphs C through F\u201d; (ii) by repealing subparagraph 1 and substituting the following subparagraph \u2014 \u201c1.a) the name, address, jurisdiction(s) of residence, TIN(s) and date and place of birth (in the case of an individual) of each Reportable Person that is an Account Holder of the account and whether the Account Holder has provided a valid selfcertification; b) in the case of any Entity that is an Account Holder and that, after application of the due diligence procedures consistent with Sections V, VI and VII, is identified as having one or more Controlling Persons that is a Reportable Person, the name, address, jurisdiction(s) of residence and TIN(s) of the Entity Regulation 19 Tax Information Authority ( International Tax Compliance) (Common Reporting Standard) (Amendment) Regulations, 2025 SL 50 of 2025 and the name, address, jurisdiction(s) of residence, TIN(s) and date and place of birth of each Reportable Person, as well as the role(s) by virtue of which each Reportable Person is a Controlling Person of the Entity and whether a valid selfcertification has been provided for each Reportable Person; and c) whether the account is a joint account, including the number of joint Account Holders.\u201d; (iii) in subparagraph 2. by inserting after the words \u201cabsence of an account number)\u201d the words \u201c, the type of account and whether the account is a Pre-existing Account or a New Account\u201d; (iv) in subparagraph 6. by deleting the word \u201cand\u201d; and (v) by inserting after subparagraph 6 the following subparagraph \u2014 \u201c6bis in the case of any Equity Interest held in an Investment Entity that is a legal arrangement, the role(s) by virtue of which the Reportable Person is an Equity Interest holder; and\u201d; (b) in Section I(C) by inserting after the words \u201cidentified as Reportable Accounts\u201d the words \u201cand whenever it is required to update the information relating to the Pre-existing Account pursuant to domestic AML\/KYC Procedures\u201d; (c) by inserting after Section I(E) the following paragraph \u2014 \u201cF.  Notwithstanding subparagraph A(5)(b) and unless the Reporting Financial Institution elects otherwise with respect to any clearly identified group of accounts, the gross proceeds from the sale or redemption of a Financial Asset are not required to be reported to the extent such gross proceeds from the sale or redemption of such Financial Asset are reported by the Reporting Financial Institution under the Crypto-Asset Reporting Framework.\u201d; (d) in Section VI(A)(2)(b) by inserting after the words \u201cAML\/KYC procedures\u201d the words \u201c, provided that such procedures are consistent with the 2012 FATF Recommendations. If the Reporting Financial Institution is not legally required to apply AML\/KYC Procedures that are consistent with the 2012 FATF Recommendations, it must apply substantially similar procedures for the purpose of determining the Controlling Persons\u201d; (e) in Section VII by inserting after paragraph A the following paragraph \u2014 Tax Information Authority ( International Tax Compliance) (Common Reporting Standard) (Amendment) Regulations, 2025 Regulation 19 SL 50 of 2025 \u201cAbis. Temporary lack of Self-Certification. In exceptional circumstances where a self-certification cannot be obtained by a Reporting Financial Institution in respect of a New Account in time to meet its due diligence and reporting obligations with respect to the reporting period during which the account was opened, the Reporting Financial Institution must apply the due diligence procedures for Pre-existing Accounts, until such self-certification is obtained and validated.\u201d; (f) in Section VIII(A) as follows \u2014 (i) by repealing subparagraph 5 and substituting the following subparagraph \u2014 \u201c5. The term \u201cDepository Institution\u201d means any Entity that \u2014 (a) accepts deposits in the ordinary course of banking or similar business; or (b) holds Specified Electronic Money Products or Central Bank Digital Currencies for the benefit of customers.\u201d; (ii) in subparagraph 6(a)(iii) by deleting the words \u201cFinancial Assets or money\u201d and substituting the words \u201cFinancial Assets, money, or Relevant Crypto-Assets\u201d; (iii) in subparagraph 6(b) after the words \u201ctrading in Financial Assets\u201d insert the words \u201cor Relevant Crypto Assets\u201d; (iv) in the words immediately below subparagraph 6(b) \u2014 (A) after the words \u201ctrading in Financial Assets\u201d insert the words \u201cor Relevant Crypto Assets\u201d; and (B) after the words \u201cEntity has been in existence.\u201d insert the words \u201cFor the purposes of subparagraph A(6)(a)(iii), the term \u201cotherwise investing, administering, or managing Financial Assets, money, or Relevant Crypto-Assets on behalf of other persons\u201d does not include the provision of services effectuating Exchange Transactions for or on behalf of customers.\u201d; (v) in subparagraph 7 after the words \u201cin a security,\u201d insert the words \u201cRelevant Crypto-Assets,\u201d; and (vi) after subparagraph 8. insert the following subparagraphs \u2014 \u201c9. The term \u201cSpecified Electronic Money Product\u201d means any product that is: a) a digital representation of a single Fiat Currency; b) issued on receipt of funds for the purpose of making payment transactions; Regulation 19 Tax Information Authority ( International Tax Compliance) (Common Reporting Standard) (Amendment) Regulations, 2025 SL 50 of 2025 c) represented by a claim on the issuer denominated in the same Fiat Currency; d) accepted in payment by a natural or legal person other than the issuer; and e) by virtue of regulatory requirements to which the issuer is subject, redeemable at any time and at par value for the same Fiat Currency upon request of the holder of the product. The term \u201cSpecified Electronic Money Product\u201d does not include a product created for the sole purpose of facilitating the transfer of funds from a customer to another person pursuant to instructions of the customer. A product is not created for the sole purpose of facilitating the transfer of funds if, in the ordinary course of business of the transferring Entity, either the funds connected with such product are held longer than 60 days after receipt of instructions to facilitate the transfer, or, if no instructions are received, the funds connected with such product are held longer than 60 days after receipt of the funds. 10. The term \u201cCentral Bank Digital Currency\u201d means any digital Fiat Currency issued by a Central Bank. 11. The term \u201cFiat Currency\u201d means the official currency of a jurisdiction, issued by a jurisdiction or by a jurisdiction\u2019s designated Central Bank or monetary authority, as represented by physical banknotes or coins or by money in different digital forms, including bank reserves, commercial bank money, electronic money products and Central Bank Digital Currencies. 12. The term \u201cCrypto-Asset\u201d means a digital representation of value that relies on a cryptographically secured distributed ledger or a similar technology to validate and secure transactions. 13. The term \u201cRelevant Crypto-Asset\u201d means any Crypto-Asset that is not a Central Bank Digital Currency, a Specified Electronic Money Product or any Crypto-Asset for which the Reporting Crypto-Asset Service Provider has adequately determined that it cannot be used for payment or investment purposes. 14. The term \u201cExchange Transaction\u201d means any: a) exchange between Relevant Crypto-Assets and Fiat Currencies; and b) exchange between one or more forms of Relevant CryptoAssets.\u201d; (g) in Section VIII(B) by repealing subparagraph (1)(a) and substituting the following \u2014 Tax Information Authority ( International Tax Compliance) (Common Reporting Standard) (Amendment) Regulations, 2025 Regulation 19 SL 50 of 2025 \u201ca) a Governmental Entity, International Organisation or Central Bank, other than: i) with respect to a payment that is derived from an obligation held in connection with a commercial financial activity of a type engaged in by a Specified Insurance Company, Custodial Institution, or Depository Institution; or ii) with respect to the activity of maintaining Central Bank Digital Currencies for Account Holders which are not Financial Institutions, Governmental Entities, International Organisations or Central Banks.\u201d; (h) in Section VIII(C)(2) as follows \u2014 (i) by deleting the words \u201cFinancial Institution in the ordinary course of a banking or similar business\u201d and substituting the words \u201cDepository Institution\u201d; and (ii) by deleting the words commencing with \u201cA Depository Account\u201d and ending with \u201ccredit interest thereon.\u201d and substituting the following \u2014 \u201cA Depository Account also includes \u2014 a) an amount held by an insurance company pursuant to a guaranteed investment contract or similar agreement to pay or credit interest therein; b) an account or notional account that represents all Specified Electronic Money Products held for the benefit of a customer; and c) an account that holds one or more Central Bank Digital Currencies for the benefit of a customer.\u201d; (i) in Section VIII(C)(9)(a) by inserting after the words \u201c31 December 2015\u201d the words \u201cor, if the account is treated as a Financial Account solely by virtue of the amendments to the Common Reporting Standard, as of 31 December 2025\u201d; (j) in Section VIII(C)(10) by inserting after the words \u201c1 January 2016\u201d the words \u201cor, if the account is treated as a Financial Account solely by virtue of the amendments to the Common Reporting Standard, on or after 1 January 2026\u201d; (k) in Section VIII(C)(17)(e) by inserting after sub-subparagraph (iv) the following sub-subparagraph \u2014 \u201cv) a foundation or capital increase of a company, provided that the account satisfies the following requirements: Regulation 19 Tax Information Authority ( International Tax Compliance) (Common Reporting Standard) (Amendment) Regulations, 2025 SL 50 of 2025 i) the account is used exclusively to deposit capital that is to be used for the purpose of the foundation or capital increase of a company, as prescribed by law; ii) any amounts held in the account are blocked until the Reporting Financial Institution obtains an independent confirmation regarding the foundation or capital increase; iii) the account is closed or transformed into an account in the name of the company after the foundation or capital increase; iv) any repayments resulting from a failed foundation or capital increase, net of service provider and similar fees, are made solely to the persons who contributed the amounts; and v) the account has not been established more than 12 months ago.\u201d; (l) in Section VIII(C)(17) by inserting after subparagraph e) the following subparagraph \u2014 \u201cebis) a Depository Account that represents all Specified Electronic Money Products held for the benefit of a customer, if the rolling average 90 day end-of-day aggregate account balance or value during any period of 90 consecutive days did not exceed USD 10,000 at any day during the calendar year or other appropriate reporting period.\u201d; (m) in Section VIII(D)(2)as follows \u2014 (i) by deleting the words \u201c(i) a corporation\u201d and substituting the words \u201c(i) an Entity\u201d; and (ii) by repealing subparagraph (ii) and substituting the following subparagraph \u2014 \u201c(ii) any Entity that is a Related Entity of an Entity described in clause (i)\u201d; (n) in Section VIII(E) by inserting after paragraph 7 the following paragraph \u2014 \u201c8. The term \u201cGovernment Verification Service\u201d is an electronic process made available by a Reportable Jurisdiction to a Reporting Financial Institution for the purposes of ascertaining the identity and tax residence of an Account Holder or Controlling Person.\u201d; and Tax Information Authority ( International Tax Compliance) (Common Reporting Standard) (Amendment) Regulations, 2025 Regulation 19 SL 50 of 2025 (o) by inserting after Section IX the following Section \u2014 \u201cSection X: Transitional Measures A. The amendments to the Common Reporting Standard are effective as of 1 January 2026. B. Notwithstanding paragraph A, under subparagraph A(1)(b) and A(6)(bis) of Section I, with respect to each Reportable Account that is maintained by a Reporting Financial Institution as of 31 December 2025 and for reporting periods ending by the second calendar year following such date, information with respect to the role(s) by virtue of which each Reportable Person is a Controlling Person or Equity Interest holder of the Entity is only required to be reported if such information is available in the electronically searchable data maintained by the Reporting Financial Institution.\u201d. Made in Cabinet the 21st day of November, 2025. 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definitions .............6\n3.\nRepeal and substitution of regulation 7 - required policies and procedures for Cayman\nReporting Financial Institutions ..................................................................................................7\n4.\nAmendment of regulation 8 - obligation of Cayman Financial Institutions to notify certain\ninformation .................................................................................................................................9\n5.\nRepeal and substitution of regulation 9 - obligation to make a return ....................................... 11\n6.\nRepeal and substitution of regulation 10 - requirements for making returns ............................. 12\n7.\nRepeal and substitution of regulation 12 - Authority\u2019s monitoring function ................................ 12\n8.\nAmendment of regulation 14 - offence pertaining to false self certification ............................... 13\n9.\nRepeal of regulation 16 - inaccurate information offence .......................................................... 13\n10.\nAmendment of regulation 17 - offence pertaining to access to confidential information ............ 13\n11.\nAmendment of regulation 24 - power to penalise ..................................................................... 14\n12.\nAmendment of regulation 28 - steps required to impose penalty .............................................. 14\n13.\nAmendment of regulation 29 - breach notice for primary penalty .............................................. 14\n14.\nAmendment of regulation 30 - considering representations and deciding primary penalty ........ 14\n15.\nAmendment of regulation 33 - automatic stay on appeal .......................................................... 15\n\nArrangement of Regulations\nTax Information Authority ( International Tax Compliance) (Common\nReporting Standard) (Amendment) Regulations, 2025\n\nPage 4\nSL 50 of 2025\nc\n\n16.\nAmendment of regulation 34 - appeal hearing and outcome .................................................... 15\n17.\nRepeal of regulation 35 - interest ............................................................................................. 15\n18.\nAmendment of regulation 38 - evidentiary provisions ............................................................... 15\n19.\nAmendment of Schedule - Common Standard on Reporting and Due Diligence for\nFinancial Account Information .................................................................................................. 15\n\nTax Information Authority ( International Tax Compliance) (Common\nReporting Standard) (Amendment) Regulations, 2025\nRegulation 1\n\nc\nSL 50 of 2025\nPage 5\n\nCAYMAN ISLANDS\n\nTax Information Authority Act\n(2021 Revision)\nTAX INFORMATION AUTHORITY\n(INTERNATIONAL TAX COMPLIANCE)\n(COMMON REPORTING STANDARD)\n(AMENDMENT) REGULATIONS, 2025\n(SL 50 of 2025)\nIn exercise of the powers conferred by section 25 of the Tax Information Authority Act\n(2021 Revision), the Cabinet makes the following Regulations \u2014\n1.\nCitation and commencement\n1.\n(1) These Regulations may be cited as the Tax Information Authority (International\nTax Compliance) (Common Reporting Standard) (Amendment) Regulations,\n2025.\n(2) With the exception of regulations 5 and 6, these Regulations come into force on\n1st January, 2026.\n(3) Regulations 5 and 6 come into force on 1st January, 2027.\n\nRegulation 2\nTax Information Authority ( International Tax Compliance) (Common\nReporting Standard) (Amendment) Regulations, 2025\n\nPage 6\nSL 50 of 2025\nc\n\n2.\nAmendment of regulation 2 of the Tax Information Authority (International\nTax Compliance) (Common Reporting Standard) Regulations (2021\nRevision) - definitions\n2.\nThe Tax Information Authority (International Tax Compliance) (Common Reporting\nStandard) Regulations (2021 Revision), in these Regulations referred to as the\n\u201cprincipal Regulations\u201d, are amended in regulation 2(1) as follows \u2014\n(a)\nby inserting, in the appropriate alphabetical sequence, the following\ndefinitions \u2014\n\u201c \u201caccurate\u201d, in relation to information provided, means the\ninformation is correct and reliable;\n\u201cadequate\u201d, in relation to the information provided under a\nregulation, means that it contains all of the details specified in that\nregulation;\n\u201cchange of circumstances\u201d includes \u2014\n(a)\na change in the information relevant to the status of an Account\nHolder or Controlling Person; or\n(b) a change that otherwise conflicts with the status of an Account\nHolder or Controlling Person;\n\u201ccompliance form\u201d means a compliance form required under\nregulation 9(2);\n\u201ccurrent\u201d, in relation to the information provided, means the\ninformation is as up to date as is reasonably practicable and\nincorporates any information relating to a change of circumstance\nthat occurred within the period to which the return, declaration, or\nany other information relates;\n\u201cgovernment entity\u201d includes a ministry, or portfolio of the\nGovernment, the Cabinet Office, the Office of the Director of Public\nProsecutions, the Office of the Ombudsman, the Audit Office, the\nParliament, a statutory body established under the laws of the Islands,\nand a public authority;\n\u201cpublic authority\u201d means a public authority as defined under section\n2 of the Public Authorities Act (2020 Revision);\n\u201cself-certification\u201d means information, by whatever name called,\nthat performs or purports to perform a purpose of a self-certification\nunder the Common Reporting Standard;\u201d;\n(b) in the definition of the words \u201cbreach notice\u201d by deleting the words \u201cin\nregulation 28(1)(a)\u201d and substituting the words \u201cin regulation 29\u201d;\n(c)\nin paragraph (a) of the definition of the words \u201cCayman Financial\nInstitution\u201d by deleting the word \u201cand\u201d and substituting the word \u201cor\u201d;\n\nTax Information Authority ( International Tax Compliance) (Common\nReporting Standard) (Amendment) Regulations, 2025\nRegulation 3\n\nc\nSL 50 of 2025\nPage 7\n\n(d) by deleting the definition of the words \u201cCommon Reporting Standard\u201d\nand substituting the following definition \u2014\n\u201c \u201cCommon Reporting Standard\u201d means the standard for\nautomatic exchange of financial account information developed by\nthe Organisation for Economic Co-Operation and Development, set\nout in the Schedule;\u201d;\n(e)\nby deleting the definition of the word \u201ccontravention\u201d and substituting\nthe following definition \u2014\n\u201c \u201ccontravention\u201d, in relation to a provision pertaining to an offence\nor a penalty, means the act or omission that constituted the offence\nand to which the penalty relates;\u201d;\n(f)\nby deleting the definition of the word \u201cgive\u201d and substituting the following\ndefinition \u2014\n\u201c \u201cgive\u201d, in relation to a notice or information, includes to deliver,\nprovide, send, transmit or make the notice or information, as\napplicable;\u201d;\n(g) by deleting the respective definitions of the words \u201cinaccurate\u201d and\n\u201cinterest\u201d;\n(h) in the definition of the words \u201cpenalty notice\u201d by deleting the words \u201cin\nregulation 28(1)(c)\u201d and substituting the words \u201cin regulation 31\u201d;\n(i)\nin paragraph (a) of the definition of the words \u201cresident in the Islands\u201d\nby inserting after the word \u201cincorporated\u201d the words \u201c, registered\u201d;\n(j)\nby deleting the definition of the word \u201creturn\u201d and substituting the\nfollowing definition \u2014\n\u201c \u201creturn\u201d (other than in the Schedule) means a return required under\nregulation 9(1)(a) or a nil return under regulation 9(1)(b);\u201d; and\n(k) by deleting the definition of the word \u201cstayed\u201d and substituting the\nfollowing definition \u2014\n\u201c \u201cstayed\u201d, in relation to a penalty, means that the penalty cannot be\nenforced \u2014\n(a) because of the operation of regulation 30(1); or\n(b) in accordance with regulation 33(1).\u201d.\n3.\nRepeal and substitution of regulation 7 - required policies and procedures\nfor Cayman Reporting Financial Institutions\n3.\nThe principal Regulations are amended by repealing regulation 7 and substituting the\nfollowing regulation \u2014\n\nRegulation 3\nTax Information Authority ( International Tax Compliance) (Common\nReporting Standard) (Amendment) Regulations, 2025\n\nPage 8\nSL 50 of 2025\nc\n\n\u201cRequired due diligence for Cayman Financial Institutions\n7.\n(1) Each Cayman Financial Institution shall establish, implement,\nmaintain and comply with written policies and procedures that\ncomply with the reporting and due diligence requirements set out in\nSections II to VII of the Common Reporting Standard.\n(2) Without limiting paragraph (1), the policies and procedures shall \u2014\n(a)\nidentify each jurisdiction in which an Account Holder or a\nControlling Person is resident for tax purposes;\n(b) apply the due diligence procedures set out in Sections II to VII\nof the Common Reporting Standard;\n(c)\nensure that valid self-certifications, in accordance with\nparagraph (4) are collected; and\n(d) ensure that any information obtained in accordance with this\nPart, or a record of the steps taken to comply with this Part, in\nrespect of a Financial Account is kept for at least six years from\nthe end of the year to which the information relates or during\nwhich the steps were taken.\n(3) Subject to the paragraph headed \u201cAbis. Temporary lack of SelfCertification.\u201d set out in Section VII of the Common Reporting\nStandard, each Cayman Financial Institution shall collect a valid selfcertification, in accordance with paragraph (4), for new accounts, on\nor before the date a Financial Account is opened.\n(4) In order for a self-certification to be valid it shall include the\nfollowing current information with respect to \u2014\n(a)\nIndividual Account Holders and Controlling Persons \u2014\n(i)\nname;\n(ii) permanent residence address;\n(iii) the jurisdiction(s) of residence for tax purposes;\n(iv) TIN or functional equivalent for each Reportable\nJurisdiction;\n(v) date of birth;\n(vi) place of birth;\n(vii) signature or attestation of the form; and\n(viii) date of signature or attestation; and\n(b) Entity Account Holders \u2014\n(i)\nname;\n(ii) address;\n(iii) the jurisdiction(s) of residence for tax purposes;\n\nTax Information Authority ( International Tax Compliance) (Common\nReporting Standard) (Amendment) Regulations, 2025\nRegulation 4\n\nc\nSL 50 of 2025\nPage 9\n\n(iv) TIN or functional equivalent for each Reportable\nJurisdiction;\n(v) the type of Reporting Financial Institution, Non-Reporting\nFinancial Institution or Non-Financial Entity, the entity is;\n(vi) signature or attestation of the form; and\n(vii) date of signature or attestation.\n(5) In this regulation, \u201cresident for tax purposes\u201d means resident\nfor income tax or corporation tax purposes or for the purpose of\nany tax imposed by the law of the jurisdiction that is of a similar\ncharacter to either of those taxes; and \u201cresidence for tax\npurposes\u201d is to be construed accordingly.\u201d.\n4.\nAmendment of regulation 8 - obligation of Cayman Financial Institutions to\nnotify certain information\n4.\nThe principal Regulations are amended in regulation 8 as follows \u2014\n(a)\nby repealing paragraphs (1) and (2) and substituting the following\nparagraphs \u2014\n\u201c(1) Each Cayman Financial Institution, other than an exempted body,\nshall submit to the Authority \u2014\n(a)\nsubject to paragraph (3A), a registration form stating the\nrequired information about the institution on or before the next\n31st January, if the entity became a Financial Institution in the\nprevious calendar year; and\n(b) if any of the required information so notified changes, a notice\nstating details of the change (a \u201cchange form\u201d),\nand any change form shall be submitted within thirty days after the\nchange occurring.\n(2) A registration form or change form shall be adequate, accurate and\ncurrent and shall be given through the electronic portal in the form\nand manner specified by the Authority.\u201d;\n(b) in paragraph (3) by deleting the words \u201cchange notice\u201d wherever they\nappear and substituting the words \u201cchange form\u201d;\n(c)\nby inserting after paragraph (3) the following paragraphs \u2014\n\u201c(3A)A Cayman Financial Institution, other than an exempted body that\nbecame a Financial Institution in 2025, shall submit the registration\nform stating the required information about the institution on or\nbefore 30th April, 2026.\n\nRegulation 4\nTax Information Authority ( International Tax Compliance) (Common\nReporting Standard) (Amendment) Regulations, 2025\n\nPage 10\nSL 50 of 2025\nc\n\n(3B) Where, prior to the commencement of the Tax Information Authority\n(International Tax Compliance) (Common Reporting Standard)\n(Amendment) Regulations, 2025, a Cayman Financial Institution \u2014\n(a)\nwas registered with the Authority; and\n(b) has not notified the Authority of a person in the Islands\nauthorised to act as its principal point of contact for compliance\nwith this Part,\nthe Cayman Financial Institution shall, on or before 31st January\n2027, submit a change form to the Authority notifying the Authority\nof the person in the Islands whom it has authorised to act as its\nprincipal point of contact for compliance with this Part.\u201d; and\n(d) by repealing paragraph (4) and substituting the following paragraph \u2014\n\u201c(4) In this regulation \u2014\n\u201cexempted body\u201d means \u2014\n(a)\nthe Cayman Islands Monetary Authority under section\n5(1) of the Monetary Authority Act (2020 Revision)\n(\u201cCIMA\u201d);\n(b) a government entity; or\n(c)\na Pension Fund of CIMA or a government entity; and\n\u201crequired information\u201d, for a Cayman Financial Institution,\nmeans \u2014\n(a)\nthe institution\u2019s name and any number given to it by the\nGeneral Registry, Cayman Islands Monetary Authority, or\nother regulatory or supervisory body;\n(b) whether the institution is a Cayman Reporting Financial\nInstitution or a Non-Reporting Financial Institution;\n(c)\nif the institution is a Cayman Reporting Financial\nInstitution, a correct statement of its classification under\nSection VIII(A) of the Common Reporting Standard;\n(d) if the institution is a Non-Reporting Financial Institution,\na correct statement of its classification under Section\nVIII(B) of the Common Reporting Standard;\n(e)\nthe date the entity became a Financial Institution; and\n(f)\nthe full name, address, business entity, position and\ncontact details (including an electronic address) of \u2014\n(i)\na person, in the Islands, that the institution has\nauthorised to be its principal point of contact for\ncompliance with this Part; and\n\nTax Information Authority ( International Tax Compliance) (Common\nReporting Standard) (Amendment) Regulations, 2025\nRegulation 5\n\nc\nSL 50 of 2025\nPage 11\n\n(ii) except in circumstances specified by the Authority,\nanother person that the institution has authorised to\ngive change forms for its principal point of contact.\u201d.\n5.\nRepeal and substitution of regulation 9 - obligation to make a return\n5.\nThe principal Regulations are amended by repealing regulation 9 and substituting the\nfollowing regulation \u2014\n\n\u201cObligation to make a return and a compliance form\n9.\n(1) Each Cayman Financial Institution, shall in each calendar year \u2014\n(a)\nmake a return to the Authority for each Reportable Account the\ninstitution maintained during the year in accordance with the\nrequirements specified in Section I of the Common Reporting\nStandard; or\n(b) if the institution did not maintain any Reportable Account in a\nReportable Jurisdiction during the year, make a nil return for\nthat Reportable Jurisdiction,\non or before the 30th of June of the year following the calendar year\nto which the return relates, together with a declaration made by the\nCayman Financial Institution that states that the information\nprovided in the return is adequate, accurate and current.\n(2) Subsequent to the filings required under paragraph (1), a Cayman\nFinancial Institution shall, for each calendar year, make and submit\nto the Authority a compliance form on or before the 30th of June of\nthe year following the year to which the compliance form relates,\ntogether with a declaration made by the Cayman Financial Institution\nthat states that the information provided in the compliance form is\nadequate, accurate and current.\n(3) A Cayman Financial Institution shall provide to the Authority\ninformation reasonably required by the Authority to ensure effective\nimplementation of, and compliance with, the reporting and due\ndiligence procedures in accordance with the Common Reporting\nStandard.\n(4) For the purposes of the information required to be reported under the\nCommon Reporting Standard \u2014\n(a)\na reference to the balance or value of an account includes a nil\nbalance or value; and\n(b) a reference to paying an amount includes crediting an amount.\n(5) The information provided under this regulation shall be adequate,\naccurate and current.\n\nRegulation 6\nTax Information Authority ( International Tax Compliance) (Common\nReporting Standard) (Amendment) Regulations, 2025\n\nPage 12\nSL 50 of 2025\nc\n\n(6) The Authority may require corrections to the return and compliance\nform by notice issued to the relevant Cayman Financial Institution\nand shall, in the notice, specify the date by which the corrections shall\nbe made.\u201d.\n6.\nRepeal and substitution of regulation 10 - requirements for making returns\n6.\nThe principal Regulations are amended by repealing regulation 10 and substituting\nthe following regulation \u2014\n\n\u201cRequirements for making a return or a compliance form\n10. (1) Returns, compliance forms, and declarations shall be submitted\nthrough the electronic portal in the form and manner specified by the\nAuthority.\n(2) The Authority shall notify Cayman Financial Institutions of the\nelectronic portal and its usage by \u2014\n(a)\na post on an official website, for their information generally; or\n(b) a notice given to any particular Cayman Financial Institution in\nquestion.\n(3) Unless the contrary is proved, the Authority shall presume that a\nreturn or compliance form accepted by the electronic portal \u2014\n(a)\nhas been submitted as required under paragraph (1); or\n(b) was submitted \u2014\n(i)\nwhen the return or compliance form was accepted by the\nelectronic portal;\n(ii) by the person who filed the return or compliance form by\nusing the electronic portal; and\n(iii) with the authority of the Cayman Financial Institution on\nwhose behalf the return or compliance form purports to\nhave been submitted.\u201d.\n7.\nRepeal and substitution of regulation 12 - Authority\u2019s monitoring function\n7.\nThe principal Regulations are amended by repealing regulation 12 and substituting\nthe following regulation \u2014\n\n\u201cAuthority\u2019s monitoring function\n12. (1) The Authority may by notice given to an entity, require the entity \u2014\n(a)\nwithin a time specified by the Authority, to provide to the\nAuthority information, including a copy of a relevant book,\ndocument or other record, or of electronically stored\ninformation; or\n\nTax Information Authority ( International Tax Compliance) (Common\nReporting Standard) (Amendment) Regulations, 2025\nRegulation 8\n\nc\nSL 50 of 2025\nPage 13\n\n(b) at a time specified by the Authority, to make available to the\nAuthority for inspection, a book, document or other record, or\nany electronically stored information,\nthat is in the entity\u2019s possession or under its control, that the\nAuthority reasonably requires to verify the classification of the entity\nor to decide whether or not information the entity gave the Authority\nwas adequate, accurate and current.\n(2) If the information that the Authority wants or wants to inspect, is\noutside of the Islands and the Authority requires the entity to bring\nthe information to the Islands, the Authority shall specify a time that\nwill enable the entity to bring the information to the Islands and the\nentity shall comply with the requirement of the Authority.\n(3) A Cayman Financial Institution shall retain for at least six years a\nbook, document or other record, including any information stored by\nelectronic means, that relates to the information required to be\nreported to the Authority under this Part.\u201d.\n8.\nAmendment of regulation 14 - offence pertaining to false self certification\n8.\nThe principal Regulations are amended in regulation 14 as follows \u2014\n(a)\nby repealing the regulation heading and substituting the following\nregulation heading \u2014\n\u201cOffence pertaining to false self-certification\u201d; and\n(b) by repealing paragraph (3) and substituting the following paragraph \u2014\n\u201c(3) In this regulation, \u201cmakes\u201d means to sign or otherwise positively\naffirm.\u201d.\n9.\nRepeal of regulation 16 - inaccurate information offence\n9.\nThe principal Regulations are amended by repealing regulation 16.\n10.\nAmendment of regulation 17 - offence pertaining to access to confidential\ninformation\n10. The principal Regulations are amended in regulation 17 as follows \u2014\n(a)\nby renumbering the regulation as paragraph (1) of regulation 17;\n(b) in paragraph (1)(a) as renumbered, by deleting the word \u201cmaterially\u201d; and\n(c)\nby inserting after paragraph (1) as renumbered, the following paragraph \u2014\n\u201c(2) In paragraph (1)(a) \u201cinaccurate\u201d means incomplete, incorrect or\nunreliable.\u201d.\n\nRegulation 11\nTax Information Authority ( International Tax Compliance) (Common\nReporting Standard) (Amendment) Regulations, 2025\n\nPage 14\nSL 50 of 2025\nc\n\n11.\nAmendment of regulation 24 - power to penalise\n11. The principal Regulations are amended in regulation 24 by inserting after paragraph\n(3) the following paragraphs \u2014\n\u201c(3A)The Authority shall not impose a continuing penalty where a primary\npenalty in the amount of fifty thousand dollars is imposed under\nparagraph (1)(a).\n(3B) Where the sum of the primary penalty and any continuing penalty\nimposed is fifty thousand dollars, the Authority shall not impose any\nadditional continuing penalties.\u201d.\n12.\nAmendment of regulation 28 - steps required to impose penalty\n12. The principal Regulations are amended in regulation 28 by repealing paragraph (1)\nand substituting the following paragraphs \u2014\n\u201c(1) Subject to paragraph (1A), where the Authority decides to impose a\npenalty, the Authority shall impose the primary penalty by \u2014\n(a)\ngiving the party a breach notice;\n(b) if regulation 30 applies, complying with that regulation; and\n(c)\ngiving the party a penalty notice.\n(1A) In the case of a contravention of regulation 9, the Authority may\nimpose a penalty by giving the party a penalty notice, without first\nhaving taken the steps under paragraph (1)(a) or (b).\u201d\n13.\nAmendment of regulation 29 - breach notice for primary penalty\n13. The principal Regulations are amended in regulation 29 as follows \u2014\n(a)\nin paragraph (1)(e) by inserting after the word \u201crepresentations\u201d the words\n\u201ctogether with supporting documentation\u201d; and\n(b) in paragraph (2) by deleting the word \u201csixty\u201d and substituting the word\n\u201cthirty\u201d.\n14.\nAmendment of regulation 30 - considering representations and deciding\nprimary penalty\n14. The principal Regulations are amended in regulation 30 as follows \u2014\n(a)\nin paragraph (1) by inserting after the word \u201crepresentations\u201d the words\n\u201ctogether with supporting documentation within the period\u201d; and\n(b) in paragraph (2) by deleting the word \u201cThe\u201d and substituting the words \u201cIn\naccordance with paragraph (1), the\u201d.\n\nTax Information Authority ( International Tax Compliance) (Common\nReporting Standard) (Amendment) Regulations, 2025\nRegulation 15\n\nc\nSL 50 of 2025\nPage 15\n\n15.\nAmendment of regulation 33 - automatic stay on appeal\n15. The principal Regulations are amended in regulation 33(1) by deleting the words \u201cor\ninterest\u201d.\n16.\nAmendment of regulation 34 - appeal hearing and outcome\n16. The principal Regulations are amended in regulation 34 as follows \u2014\n(a)\nin paragraph (3)(b) by deleting the words \u201cand for interest\u201d; and\n(b) in paragraph (4) by deleting the words \u201cboth the penalty and interest are\u201d\nand substituting the words \u201cthe penalty is\u201d.\n17.\nRepeal of regulation 35 - interest\n17. The principal Regulations are amended by repealing regulation 35.\n18.\nAmendment of regulation 38 - evidentiary provisions\n18. The principal Regulations are amended in regulation 38 as follows \u2014\n(a)\nin paragraph (1) by deleting the words \u201cor interest\u201d; and\n(b) in paragraph (3) as follows \u2014\n(i)\nin subparagraphs (d) and (f), respectively, by deleting the words\n\u201cCayman Reporting Financial Institution\u201d and substituting the words\n\u201cCayman Financial Institution\u201d; and\n(ii) in subparagraph (j) by deleting the words \u201cor interest\u201d.\n19.\nAmendment of Schedule - Common Standard on Reporting and Due\nDiligence for Financial Account Information\n19. The principal Regulations are amended in the Schedule as follows \u2014\n(a)\nin Section I(A) as follows \u2014\n(i)\nby repealing the words \u201cSubject to paragraphs C through E\u201d and\nsubstituting the words \u201cSubject to paragraphs C through F\u201d;\n(ii) by repealing subparagraph 1 and substituting the following\nsubparagraph \u2014\n\u201c1.a) the name, address, jurisdiction(s) of residence, TIN(s) and date\nand place of birth (in the case of an individual) of each\nReportable Person that is an Account Holder of the account and\nwhether the Account Holder has provided a valid selfcertification;\nb)\nin the case of any Entity that is an Account Holder and that,\nafter application of the due diligence procedures consistent with\nSections V, VI and VII, is identified as having one or more\nControlling Persons that is a Reportable Person, the name,\naddress, jurisdiction(s) of residence and TIN(s) of the Entity\n\nRegulation 19\nTax Information Authority ( International Tax Compliance) (Common\nReporting Standard) (Amendment) Regulations, 2025\n\nPage 16\nSL 50 of 2025\nc\n\nand the name, address, jurisdiction(s) of residence, TIN(s) and\ndate and place of birth of each Reportable Person, as well as the\nrole(s) by virtue of which each Reportable Person is a\nControlling Person of the Entity and whether a valid selfcertification has been provided for each Reportable Person; and\nc)\nwhether the account is a joint account, including the number of\njoint Account Holders.\u201d;\n(iii) in subparagraph 2. by inserting after the words \u201cabsence of an\naccount number)\u201d the words \u201c, the type of account and whether the\naccount is a Pre-existing Account or a New Account\u201d;\n(iv) in subparagraph 6. by deleting the word \u201cand\u201d; and\n(v) by inserting after subparagraph 6 the following subparagraph \u2014\n\u201c6bis\nin the case of any Equity Interest held in an Investment\nEntity that is a legal arrangement, the role(s) by virtue of\nwhich the Reportable Person is an Equity Interest holder;\nand\u201d;\n(b) in Section I(C) by inserting after the words \u201cidentified as Reportable\nAccounts\u201d the words \u201cand whenever it is required to update the\ninformation relating to the Pre-existing Account pursuant to domestic\nAML\/KYC Procedures\u201d;\n(c)\nby inserting after Section I(E) the following paragraph \u2014\n\u201cF.  Notwithstanding subparagraph A(5)(b) and unless the Reporting\nFinancial Institution elects otherwise with respect to any clearly\nidentified group of accounts, the gross proceeds from the sale or\nredemption of a Financial Asset are not required to be reported to the\nextent such gross proceeds from the sale or redemption of such\nFinancial Asset are reported by the Reporting Financial Institution\nunder the Crypto-Asset Reporting Framework.\u201d;\n(d) in Section VI(A)(2)(b) by inserting after the words \u201cAML\/KYC\nprocedures\u201d the words \u201c, provided that such procedures are consistent with\nthe 2012 FATF Recommendations. If the Reporting Financial Institution\nis not legally required to apply AML\/KYC Procedures that are consistent\nwith the 2012 FATF Recommendations, it must apply substantially similar\nprocedures for the purpose of determining the Controlling Persons\u201d;\n(e)\nin Section VII by inserting after paragraph A the following paragraph \u2014\n\nTax Information Authority ( International Tax Compliance) (Common\nReporting Standard) (Amendment) Regulations, 2025\nRegulation 19\n\nc\nSL 50 of 2025\nPage 17\n\n\u201cAbis.\nTemporary\nlack\nof\nSelf-Certification. In\nexceptional\ncircumstances where a self-certification cannot be obtained by a Reporting\nFinancial Institution in respect of a New Account in time to meet its due\ndiligence and reporting obligations with respect to the reporting period\nduring which the account was opened, the Reporting Financial Institution\nmust apply the due diligence procedures for Pre-existing Accounts, until\nsuch self-certification is obtained and validated.\u201d;\n(f)\nin Section VIII(A) as follows \u2014\n(i)\nby repealing subparagraph 5 and substituting the following\nsubparagraph \u2014\n\u201c5.\nThe term \u201cDepository Institution\u201d means any Entity\nthat \u2014\n(a)\naccepts deposits in the ordinary course of banking or\nsimilar business; or\n(b) holds Specified Electronic Money Products or\nCentral Bank Digital Currencies for the benefit of\ncustomers.\u201d;\n(ii) in subparagraph 6(a)(iii) by deleting the words \u201cFinancial Assets or\nmoney\u201d and substituting the words \u201cFinancial Assets, money, or\nRelevant Crypto-Assets\u201d;\n(iii) in subparagraph 6(b) after the words \u201ctrading in Financial Assets\u201d\ninsert the words \u201cor Relevant Crypto Assets\u201d;\n(iv) in the words immediately below subparagraph 6(b) \u2014\n(A) after the words \u201ctrading in Financial Assets\u201d insert the words\n\u201cor Relevant Crypto Assets\u201d; and\n(B) after the words \u201cEntity has been in existence.\u201d insert the words\n\u201cFor the purposes of subparagraph A(6)(a)(iii), the term\n\u201cotherwise investing, administering, or managing Financial\nAssets, money, or Relevant Crypto-Assets on behalf of other\npersons\u201d does not include the provision of services effectuating\nExchange Transactions for or on behalf of customers.\u201d;\n(v) in subparagraph 7 after the words \u201cin a security,\u201d insert the words\n\u201cRelevant Crypto-Assets,\u201d; and\n(vi) after subparagraph 8. insert the following subparagraphs \u2014\n\u201c9. The term \u201cSpecified Electronic Money Product\u201d means any\nproduct that is:\na)\na digital representation of a single Fiat Currency;\nb)\nissued on receipt of funds for the purpose of making payment\ntransactions;\n\nRegulation 19\nTax Information Authority ( International Tax Compliance) (Common\nReporting Standard) (Amendment) Regulations, 2025\n\nPage 18\nSL 50 of 2025\nc\n\nc)\nrepresented by a claim on the issuer denominated in the same\nFiat Currency;\nd)\naccepted in payment by a natural or legal person other than the\nissuer; and\ne)\nby virtue of regulatory requirements to which the issuer is\nsubject, redeemable at any time and at par value for the same\nFiat Currency upon request of the holder of the product.\n\nThe term \u201cSpecified Electronic Money Product\u201d does not\ninclude a product created for the sole purpose of facilitating the\ntransfer of funds from a customer to another person pursuant to\ninstructions of the customer. A product is not created for the\nsole purpose of facilitating the transfer of funds if, in the\nordinary course of business of the transferring Entity, either the\nfunds connected with such product are held longer than 60 days\nafter receipt of instructions to facilitate the transfer, or, if no\ninstructions are received, the funds connected with such product\nare held longer than 60 days after receipt of the funds.\n10. The term \u201cCentral Bank Digital Currency\u201d means any digital Fiat\nCurrency issued by a Central Bank.\n11. The term \u201cFiat Currency\u201d means the official currency of a\njurisdiction, issued by a jurisdiction or by a jurisdiction\u2019s designated\nCentral Bank or monetary authority, as represented by physical\nbanknotes or coins or by money in different digital forms, including\nbank reserves, commercial bank money, electronic money products\nand Central Bank Digital Currencies.\n12. The term \u201cCrypto-Asset\u201d means a digital representation of value that\nrelies on a cryptographically secured distributed ledger or a similar\ntechnology to validate and secure transactions.\n13. The term \u201cRelevant Crypto-Asset\u201d means any Crypto-Asset that is\nnot a Central Bank Digital Currency, a Specified Electronic Money\nProduct or any Crypto-Asset for which the Reporting Crypto-Asset\nService Provider has adequately determined that it cannot be used for\npayment or investment purposes.\n14. The term \u201cExchange Transaction\u201d means any:\na)\nexchange between Relevant Crypto-Assets and Fiat Currencies;\nand\nb)\nexchange between one or more forms of Relevant CryptoAssets.\u201d;\n(g) in Section VIII(B) by repealing subparagraph (1)(a) and substituting the\nfollowing \u2014\n\nTax Information Authority ( International Tax Compliance) (Common\nReporting Standard) (Amendment) Regulations, 2025\nRegulation 19\n\nc\nSL 50 of 2025\nPage 19\n\n\u201ca) a Governmental Entity, International Organisation or Central\nBank, other than:\ni)\nwith respect to a payment that is derived from an\nobligation held in connection with a commercial financial\nactivity of a type engaged in by a Specified Insurance\nCompany, Custodial Institution, or Depository Institution;\nor\nii)\nwith respect to the activity of maintaining Central Bank\nDigital Currencies for Account Holders which are not\nFinancial\nInstitutions,\nGovernmental\nEntities,\nInternational Organisations or Central Banks.\u201d;\n(h) in Section VIII(C)(2) as follows \u2014\n(i)\nby deleting the words \u201cFinancial Institution in the ordinary course of\na banking or similar business\u201d and substituting the words\n\u201cDepository Institution\u201d; and\n(ii) by deleting the words commencing with \u201cA Depository Account\u201d\nand ending with \u201ccredit interest thereon.\u201d and substituting the\nfollowing \u2014\n\u201cA Depository Account also includes \u2014\na)\nan amount held by an insurance company pursuant to a\nguaranteed investment contract or similar agreement to pay or\ncredit interest therein;\nb)\nan account or notional account that represents all Specified\nElectronic Money Products held for the benefit of a customer;\nand\nc)\nan account that holds one or more Central Bank Digital\nCurrencies for the benefit of a customer.\u201d;\n(i)\nin Section VIII(C)(9)(a) by inserting after the words \u201c31 December 2015\u201d\nthe words \u201cor, if the account is treated as a Financial Account solely by\nvirtue of the amendments to the Common Reporting Standard, as of 31\nDecember 2025\u201d;\n(j)\nin Section VIII(C)(10) by inserting after the words \u201c1 January 2016\u201d the\nwords \u201cor, if the account is treated as a Financial Account solely by virtue\nof the amendments to the Common Reporting Standard, on or after 1\nJanuary 2026\u201d;\n(k) in Section VIII(C)(17)(e) by inserting after sub-subparagraph (iv) the\nfollowing sub-subparagraph \u2014\n\u201cv) a foundation or capital increase of a company, provided\nthat the account satisfies the following requirements:\n\nRegulation 19\nTax Information Authority ( International Tax Compliance) (Common\nReporting Standard) (Amendment) Regulations, 2025\n\nPage 20\nSL 50 of 2025\nc\n\ni)\nthe account is used exclusively to deposit capital that\nis to be used for the purpose of the foundation or\ncapital increase of a company, as prescribed by law;\nii)\nany amounts held in the account are blocked until the\nReporting\nFinancial\nInstitution\nobtains\nan\nindependent confirmation regarding the foundation\nor capital increase;\niii) the account is closed or transformed into an account\nin the name of the company after the foundation or\ncapital increase;\niv) any repayments resulting from a failed foundation or\ncapital increase, net of service provider and similar\nfees, are made solely to the persons who contributed\nthe amounts; and\nv)\nthe account has not been established more than 12\nmonths ago.\u201d;\n(l)\nin Section VIII(C)(17) by inserting after subparagraph e) the following\nsubparagraph \u2014\n\u201cebis)\na Depository Account that represents all Specified\nElectronic Money Products held for the benefit of a\ncustomer, if the rolling average 90 day end-of-day\naggregate account balance or value during any period\nof 90 consecutive days did not exceed USD\n 10,000 at any day during the calendar year or other\nappropriate reporting period.\u201d;\n(m) in Section VIII(D)(2)as follows \u2014\n(i)\nby deleting the words \u201c(i) a corporation\u201d and substituting the words\n\u201c(i) an Entity\u201d; and\n(ii) by repealing subparagraph (ii) and substituting the following\nsubparagraph \u2014\n\u201c(ii) any Entity that is a Related Entity of an Entity described\nin clause (i)\u201d;\n(n) in Section VIII(E) by inserting after paragraph 7 the following\nparagraph \u2014\n\u201c8. The term \u201cGovernment Verification Service\u201d is an electronic\nprocess made available by a Reportable Jurisdiction to a\nReporting Financial Institution for the purposes of ascertaining\nthe identity and tax residence of an Account Holder or\nControlling Person.\u201d; and\n\nTax Information Authority ( International Tax Compliance) (Common\nReporting Standard) (Amendment) Regulations, 2025\nRegulation 19\n\nc\nSL 50 of 2025\nPage 21\n\n(o) by inserting after Section IX the following Section \u2014\n\n\u201cSection X: Transitional Measures\nA.\nThe amendments to the Common Reporting Standard are\neffective as of 1 January 2026.\nB.\nNotwithstanding paragraph A, under subparagraph A(1)(b) and\nA(6)(bis) of Section I, with respect to each Reportable Account\nthat is maintained by a Reporting Financial Institution as of 31\nDecember 2025 and for reporting periods ending by the second\ncalendar year following such date, information with respect to\nthe role(s) by virtue of which each Reportable Person is a\nControlling Person or Equity Interest holder of the Entity is\nonly required to be reported if such information is available in\nthe electronically searchable data maintained by the Reporting\nFinancial Institution.\u201d.\nMade in Cabinet the 21st day of November, 2025.\nKim Bullings\nClerk of the Cabinet","akn_extracted_at":"2026-06-22 15:42:12.731235+00","cms_id":"2025-0050S","law_type":"amending","year":"2025","number":"0050S","title":"Tax Information Authority ( International Tax Compliance) (Common Reporting Standard) (Amendment) Regulations, 2025 (SL 50 of 2025)","status":"in_force"},"provenance":{"files":[{"file_id":"6859","expr_id":"2081","kind":"akn_xml","filename":"2025-0050S.akn.xml","source_url":null,"storage_path":"\/Users\/q\/kyleg-data\/working\/AMENDING\/2025\/2025-0050S\/2025-0050S.akn.xml","content_md5":"8b5658c491308b6873535888e30c462f","byte_size":"40919","http_last_modified":null,"fetched_at":"2026-06-22 15:42:12.890125+00"},{"file_id":"4161","expr_id":"2081","kind":"pristine_pdf","filename":"2025-0050S.pdf","source_url":"\/cms\/images\/LEGISLATION\/AMENDING\/2025\/2025-0050S\/2025-0050S.pdf","storage_path":"\/Users\/q\/kyleg-data\/pristine\/AMENDING\/2025\/2025-0050S\/2025-0050S.pdf","content_md5":"408453eda86dde5f485124b468224c85","byte_size":"427820","http_last_modified":null,"fetched_at":"2026-06-21 23:09:38.205537+00"},{"file_id":"4162","expr_id":"2081","kind":"working_pdf","filename":"2025-0050S.pdf","source_url":"\/cms\/images\/LEGISLATION\/AMENDING\/2025\/2025-0050S\/2025-0050S.pdf","storage_path":"\/Users\/q\/kyleg-data\/working\/AMENDING\/2025\/2025-0050S\/2025-0050S.pdf","content_md5":"408453eda86dde5f485124b468224c85","byte_size":"427820","http_last_modified":null,"fetched_at":"2026-06-21 23:09:38.205537+00"}],"paragraph_count":11,"latest_history":null},"quality":{"expr_id":"2081","doc_id":"2081","quality_state":"needs_review","quality_score":"80","needs_human_review":"t","deterministic_categories":"{commencement_metadata_problem,duplicate_text,page_header_footer_noise}","llm_categories":"{}","repair_actions":"{collapse_duplicate_text,strip_page_furniture,verify_commencement_metadata}","finding_severity_counts":"{\"low\": 2, \"medium\": 1}","finding_summary":"repeated line furniture detected: cayman islands x3; tax information authority act x3; 2021 revision x3; duplicate-line ratio is 13.14%","assessed_at":"2026-06-22 15:29:46.662403+00","updated_at":"2026-06-22 15:29:46.662403+00"}}