FATCA / CRS Indicia

Identification of accounts for both FATCA and CRS use Indicia. The key criteria are largely the same with differences as detailed below.

FATCA Indicia

When seeking to classify whether an account holder or an individual connected to an entity is a US Person the following indicia should be used:

  1. Documentation suggesting they are US residents or US citizens
  2. A US registered or correspondence address
  3. A US place of birth
  4. Other details, such as “care of” address, holding address or PO Box
  5. Power of attorney or signatory authority granted to a person in the US
  6. Standing instructions to transfer funds to an account in the US or directions received from a US address
  7. A US telephone number

CRS Indicia

When seeking to classify whether an account holder or an individual connected to an entity is a resident of one of the participating jurisdictions the following indicia should be used:

  1. Identification of the Account Holder as a resident of a Reportable (or future reportable) Jurisdiction
  2. Current mailing or residence address (including a post office box) in a Reportable Jurisdiction
  3. One or more telephone numbers if a Reportable Jurisdiction
  4. Standing instructions (other than with respect to a Depositary Account) to transfer funds to an account maintained in a Reportable Jurisdiction
  5. Currently effective power of attorney or signatory authority granted to a person with an address in a Reportable Jurisdiction
  6. A “hold mail” instruction or “in-care-of” address in a Reportable Jurisdiction if the Reporting Financial Institution does not have any other address on file for the Account holder