1st December 2022
The FIAU acknowledges that there may be justified exceptions to validation rule L3.044 for which an acceptable workaround can be found hereunder.
Validation Rule L3.044 ensures that the registration number for the same registration country is unique across all Non-Natural Persons. Nevertheless, the FIAU understands that there are scenarios whereby the subject person may opt for the creation of distinct client profiles for the same body corporate to ring-fence the following types of accounts:
- Accounts designated for different trusts
- Accounts designated for different sub-funds
From a CBAR point of view, the above scenarios will result in multiple non-natural persons and hence the submission will be in breach of validation rule L3.044.
In acknowledgement of this limitation, it is permissible that reporting entities continue to report such trusts and sub-funds as separate records (e.g., ‘ABC Trustee Services Limited as trustees of Trust 1’, ‘ABC Trustee Services Limited as trustees of Trust 2’ and so on). To adhere with validation L3.044, the client record’s unique ID should be appended to the registration number following a hash sign (e.g., C12345#00991, C12345#00992). This approach will ensure a unique registration number for each person.
Reporting entities who opt to segregate such funds in separate accounts or in pooled accounts may continue doing so. If there are scenarios other than the ones mentioned above which may warrant the use of this workaround, Reporting Entities are required to formally notify the FIAU beforehand via email on [email protected] with the proposed approach for consideration at the FIAU’s discretion.