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HMRC internal manual

International Exchange of Information Manual

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HM Revenue & Customs
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Due Diligence: General Requirements: Alternative Procedures for Pre-Existing Accounts

Due Diligence: General Requirements: Alternative Procedures for Pre-Existing Accounts

Reporting Financial Institutions may apply

  1. The due diligence procedures for new accounts to pre-existing accounts, and/or
  2. The due diligence procedures for High Value Accounts to Lower Value Accounts.

 

Where a Financial Institution chooses to apply one or both of these alternatives it may do so with respect to all its pre-existing accounts or, separately, to any clearly identified group of such accounts. A group of accounts may, for example, be those maintained by a particular line of business or those maintained in a particular location.

Where a Financial Institution chooses to apply the new account procedures to pre-existing accounts the rules that otherwise apply to pre-existing accounts continue to apply. For example, the financial institution can still rely on the exception for reporting a TIN [see IEIM402040] or date of birth [see IEIM402180] if it is not in its records and is not otherwise required to be collected by domestic law. Similarly it may rely on the residence address test for CRS and DAC purposes [see IEIM402680] if applying new account procedures to pre-existing Lower Value Accounts.