103020 – Due Diligence: Pre-Existing Individual Accounts: High Value Accounts: Change of Circumstance

Once the due diligence procedures have been completed the Account Holder will be identified as either a non-Reportable Person or reportable to one or more jurisdictions with which the UK has agreements to exchange information. That status will not change until a change of circumstance is identified by the financial institution.

A change of circumstance includes any change to, or addition of, information in relation to an Account Holder’s status and includes details of any addition, substitution or other change of an Account Holder as well as information in respect of any accounts associated with the Account Holder, that is, accounts associated through the aggregation rules or where a new account has been treated as a pre-existing obligation for due diligence purposes.

A change of circumstance is only relevant if the new information affects the status of the Account Holder for the purposes of the exchange of information agreements, whether that is based on the due diligence procedures or from a self-certification. For example, a person who has been identified as reportable to Jersey provides the financial institution with details of a change of residential address to a property in France. That is evidence that there has been a change of circumstance affecting the reportable status of the Account Holder. If, however, the new address had also been in Jersey the reportable status established earlier would not be affected and no further action would be required on the part of the financial institution.

Once a change of circumstance has been identified the financial institution must request a self certification or other documentation from the Account Holder to establish whether the individual is a Reportable Person and, if so, to which jurisdiction the reportable information should be sent. If the Account Holder fails to respond to the request, the financial institution should treat the Account Holder as reportable to each jurisdiction for which it holds indicia unless it can apply the curing procedure described at AEIM102880.