08.04 – Identification of an entity as a Non-Participating Financial Institution

If the entity is a UK Financial Institution or a Financial Institution in another Partner Jurisdiction, no further review, identification or reporting will normally be required. The exception to this is if the Financial Institution becomes a Non-Participating Financial Institution following significant non-compliance.

If the account holder is a Financial Institution, but not a UK Financial Institution, Financial Institution in another Partner Jurisdiction or a Participating Financial Institution, then the entity is treated as a Non-Participating Financial Institution.

This applies unless the Reporting Financial Institution:

  • obtains a self certification from the entity stating that it is a Certified Deemed-Compliant Financial Institution, an Exempt Beneficial Owner, or an Excepted Financial Institution; or
  • verifies its status as a Participating Financial Institution or Registered Deemed Compliant Financial Institution for instance by obtaining a GIIN (see 8.3).

If the account holder is a Non-Participating Financial Institution, then reports on certain payments made to such entities will be required. (See Section 9.4)