IEIM403125 - Due Diligence: New Individual Accounts: Preexisting customers
New Individual Accounts: Preexisting customers
New accounts are those opened on or after the date that the exchange of information regimes ‘switch on’ under the timelines for reporting [see IEIM400520 for FATCA and IEIM400580 for CRS]. New individual accounts are accounts where the Reportable Person [see IEIM403440] is an individual.
For accounts that become Financial Accountssolely due to the implementation of CRS2.0 [IEIM401540], the New Account ‘switch on’ date is 1 January 2026.
For CRS purposes, certain new accounts of preexisting customers may be classified as Preexisting Accounts and be subject to Preexisting Account due diligence provided certain conditions are satisfied.
The conditions are set out in paragraph 82 of the Commentary to Section VIII.C(9) of the CRS.
Where accounts are classified as Preexisting Accounts under these rules, then for CRS2.0 reporting they should be reported as Preexisting Accounts.
Example:
A Financial Institution classifies a cash savings Depository Account opened in 2021 as a Preexisting Account, since it meets the criteria to be a Preexisting Account set out in the optional paragraph C(9) to Section VIII of the CRS. The Account Holder already held an account with the same Financial Institution which was opened in 2013; both accounts are treated as a single Financial Account for due diligence purposes; the Financial Institution is permitted to rely on AML/KYC procedures performed for the account opened in 2013, and the opening of the account in 2021 did not require any new, additional or amended information from the customer other than for CRS purposes. For the calendar year 2026, both accounts should be reported as Preexisting Accounts.
Where accounts have been acquired after the ‘switch on’ date due to a merger or acquisition [See IEIM404120] and are classified as Preexisting Accounts, then for CRS2.0 reporting they should be reported as Preexisting Accounts.