07.05 – Identification of an entity as a Financial Institution

In order to identify whether an entity is a Financial Institution, information maintained for regulatory or customer relationship purposes (including information collected as part of any AML/KYC procedure) or a Global Intermediary Identification Number can be relied upon.

If the entity is a non-US Financial Institution, including Non-Reporting Financial Institutions listed in Annex II (both Exempt Beneficial Owners and Deemed Compliant Financial Institutions) then that account is not a ‘Reportable Account’, however, there may still be reporting obligations if the entity is a Non-Participating Financial Institution.

If the entity is a US Financial Institution, then that account will NOT be a ‘Reportable Account’ if the Financial Institution is included in the list of exceptions for Specified US Persons at definition gg.