IEIM403500 - Due Diligence: Special Due Diligence Rules: Reliance on Self-Certification
Source: gov.uk (2025-11-07)


Due Diligence: Special Due Diligence Rules: Reliance on Self-Certification

Where information already held by a Financial Institution, including knowledge about the customer held by a relationship manager, conflicts with any statements or self-certification, or the Financial Institution has reason to know that the self-certification or other documentary evidence is incorrect, it may not rely on that evidence or self-certification.

A Financial Institution will be considered to have reason to know that a self-certification or other documentation associated with an account is unreliable or incorrect if, based on the relevant facts, a reasonably prudent person would know this to be the case [see IEIM403180].

A Financial Institution will have reason to know that a self-certification is unreliable or incorrect if the self-certification does not contain a TIN and the information disseminated by the OECD indicates that the Reportable Jurisdiction issues TINs to all tax residents.

Example 1:

A self-certification shows Germany as the jurisdiction of tax residence but no TIN is provided. The OECD information confirms that Germany issues TINs to all tax residents. The self-certification is invalid.

Example 2:

The facts are the same as for example 1 above, except that the Account Holder has explained that they have only recently moved to Germany and have not yet been issued a TIN. The self-certification is temporarily valid however the Financial Institution must obtain the TIN from the Account Holder within 12 months, otherwise there will be a change in circumstancesand the self-certification will cease to be valid.

Example 3:

A self-certification for an individual shows India as the jurisdiction of tax residence but no TIN is provided. The Account Holder explains that they have not been issued a TIN. The OECD information confirms that India does not issue TINs to all tax resident individuals. The self-certification is valid.

Citizenship by investment (CBI) and residence by investment (RBI) schemes

Many jurisdictions allow a foreign individual to obtain citizenship or temporary or permanent residence rights on the basis of local investments or for a flat fee (CBI/RBI schemes). Some of these schemes may potentially be misused to circumvent reporting under the CRS, for example those that give individuals access to low personal income tax rates on offshore financial assets and do not require significant physical presence in the jurisdiction.The OECD has analysed over 100 CBI/RBI schemes and identifiedthose presenting the highest risks to the integrity of the CRS. The results are published on the OECD’s website [https://web-archive.oecd.org/tax/automatic-exchange/crs-implementation-and-assistance/residence-citizenship-by-investment/index.htm].

Financial Institutions should take this information into account when confirming the reasonableness of self-certifications. Where the Financial Institution has doubts concerning the tax residency(ies) of an Account Holder or Controlling Person related to the fact that such person is claiming residence in a jurisdiction offering a potentially high-risk CBI/RBI scheme, the Financial Institution should not rely on such self-certification until it has taken further measures to ascertain the tax residency(ies) of such persons, including through raising further questions, to determine whether the self-certification passes the reasonableness test.

Reliance upon an audited financial statement

Financial Institutions may rely upon an audited financial statement to establish that an Account Holder meets a certain income or asset threshold, but are not obliged to where the entity’s status can be established from other information or documentation that it holds.

If a Financial Institution does rely upon an audited financial statement to establish a status for an Account Holder, it has reason to know that the status claimed is unreliable or incorrect only if the audited financial statement for the Account Holder or the notes or footnotes to the financial statement conflicts with the self-certification provided to it.

If a Reporting Financial Institution relies upon an audited financial statement to establish a status for an Account Holder that does not require the Account Holder to meet an asset or income threshold, it will be required to review only the notes or footnotes to the financial statement to determine whether the financial statement supports the claimed status. If a Financial Institution does rely upon other documentation to establish the Account Holder’s status there is no need to review any financial statements that may have been provided to it as part of the account opening.

Reliance upon other documentation

Where a Financial Institution relies on organisational documents to establish that an Account Holder has a particular status, it will only be required to review the documents to the extent needed to establish that the requirements applicable to the particular status are met.