02.0703 – Depository Accounts

Many Financial Institutions that fall under the Financial Institution with a Local Client Base category for the US agreement are Depository Institutions that maintain only Depository Accounts.

For most Depository Accounts, the two steps outlined above will be the extent of the electronic review for Individual Accounts under $1,000,000. If the Financial Institution searches its database for non-UK addresses (including for power of attorney or signatory authority), and either:

  • searches its database for positive, current evidence of non-UK tax residence, or
  • does not keep an electronically searchable record of the Account Holder’s tax residence,

then the Financial Institution will have completed the indicia checks and, subject to ’repairing’ any indicia found (see sections 6-9 of this guidance), they will need to report all accounts identified as belonging to CD or Gibraltar Specified Persons.