05.09 – One or more US telephone numbers associated with the account

Where the indicia found is one or more US telephone numbers associated with the account, it must be reported unless the UK Financial Institution obtains or currently maintains a record of the following:

If all the telephone numbers associated with the account are US telephone numbers:

  • a self certification that the account holder is neither a US citizen nor a US resident for tax purposes; and
  • a form of acceptable documentary evidence which establishes the account holder’s non-US status. See Section 4.2.

If there are both US and non-US telephone numbers associated with the account:

  • a self certification that the account holder is neither a US citizen nor a US resident for tax purposes; or
  • a form of acceptable documentary evidence which establishes the account holder’s non-US status. See Section 4.2.

Where there is uncertainty whether a phone number is US (for example a mobile phone number), a Financial Institution should take reasonable steps (in accordance with the relevant due diligence requirements for the type of account) to establish whether or not it is a US phone number. It should not then be treated as a US phone number if its status remains uncertain.

In the case of any number that is known not to relate to a telephone, for example, a permanent fax number, the number should not be treated as a US indicia. However if there is any doubt over the function, or the number has a combined function at least one of which is as a phone number, the number should be treated as US indicia if it is a US number.