03.0202 – Governmental Entities

The following NFFEs that will be Active for reporting to the US, will also be Active for the Isle of Man, Guernsey, Jersey and Gibraltar, but the definition for Isle of Man, Guernsey, Jersey and Gibraltar reporting has been redrafted so that a single test can be used for all jurisdictions.

Under the regulations to implement the US IGA, an NFFE that is a non-US Government, central bank or international organisation (see Section 2.6 US Guidance) will be an Active NFFE.

Under the regulations to implement CD and Gibraltar reporting this definition has been expanded to include ANY of the following:

  • a government
  • a political subdivision of such government
  • a public body performing a function of such government
  • a political subdivision thereof
  • an Entity wholly owned by one or more of the preceding

This means that for CD and Gibraltar reporting an entity only needs to be tested once to qualify as a governmental entity as the test is the same concerning all jurisdictions. It does not have to be tested separately concerning each jurisdiction.

International Organisations are not named as Active NFFEs as they are detailed separately as Exempt Beneficial Owners and so there will be no reporting obligation regarding accounts held by these organisations.