IEIM403040 - Due Diligence: Pre-Existing Individual Accounts: Higher Value Accounts: Hold Mail or In-Care-Of Address Only

Due Diligence: Pre-Existing Individual Accounts: Higher Value Accounts: Hold Mail or In-Care-Of Address Only

For CRS purposes

If either

• a hold mail instruction, or
• an “in-care-of” address in a Reportable Jurisdiction

is discovered in the enhanced review of High Value Accounts, and no other address or indicia of residence are identified for the Account Holder, the Financial Institution must request a self-certification or other documentary evidence from the Account Holder to establish the jurisdiction of tax residence of the Account Holder.

If the attempt to obtain a self-certification or documentary evidence from the Account Holder is not successful, the Financial Institution is required to treat the Account Holder as an undocumented account [see IEIM403100] for CRS.

The concept of an ‘undocumented account’ only exists for CRS reporting purposes. An undocumented account must be reported to HMRC using country code GB.

For FATCA purposes

If any in-care-of address or a hold mail instruction is discovered in the enhanced review of High Value Accounts, and no other address or indicia of residence are identified for the Account Holder, the Financial Institution must treat this as U.S. indicia and therefore as a U.S. Reportable Account unless it obtains a self-certification or other documentary evidence from the Account Holder to establish that the Account Holder is not a U.S. citizen or resident in the U.S. for tax purposes.