IEIM402320 - Reportable Information: Reasonable Efforts to Obtain

Reportable Information: Reasonable Efforts to Obtain

Where a Financial Institution does not hold information in its records [see IEIM402300] on either the Account Holder’s taxpayer identification number [see IEIM402040] or date of birth [see IEIM402180] it is expected to make reasonable efforts to obtain the information by the end of the second calendar year following the year in which the account is identified as reportable.

From 1 January 2026, reasonable efforts to obtain tax identification numbers and dates of birth should continue to be made whenever the Financial Institutionis required to update the information relating to the Preexisting Account pursuant to AML/KYC procedures.  

Reasonable efforts require genuine attempts to obtain the information and would include all or any of the following:

  • Contacting the Account Holder by mail, in-person or telephone and could include requests made as part of other documentation;
  • Electronic contact such as facsimiles or e-mail;
  • Reviewing electronically searchable information maintained by a related entity in accordance with the aggregation principles [see IEIM406560].

Reasonable efforts do not require the closing, blocking or transferring of an account, nor conditioning or otherwise limiting its use, simply because the Account Holder does not comply with a request for this information.

Reasonable efforts may continue to be made at any time after the above mentioned period if the Financial Institution so chooses.