Ministry of Finance, The Bahamas, Case Study

The Bahamas has transmitted FATCA filings since 2015. The system permitted the submission of files in either Excel or the IRS required XML format. The process was somewhat manual and required technical intervention to upload and transfer files to the IRS’ International Data Exchange Service. While the process had been improved over time, and while it was convenient for the FIs that might have been challenged with the production of files in XML format, it still placed undue responsibility on the Competent Authority for automated file format conversion from Excel to XML.

Financial Institutions who had experience in using Vizor’s portal for other jurisdictions also made requests for a more intuitive interface. Smaller filers with fewer clients were looking for a simple web form instead of the requirement to produce Excel or fully formatted XML files.

In 2017 the Competent Authority went to market, looking for a system that could meet both the existing FATCA needs and also the requirement to make Common Reporting Standard (CRS) exchanges the following year.

“The strength of any provider is tested when an issue arises. We were pleased that Vizor recognised the importance of the project to The Bahamas and committed all resources needed to resolve any issues that arose. This focus and expertise ensured a smooth implementation and a successful project.”

Catherine Gibson, Ministry of Finance

The Bahamas uses the Vizor AEOI solution for both CRS and FATCA. The project started in May 2018 and was completed in a matter of weeks. It provided a common portal to Financial Institutions to make filings in July of the same year. The project plan was flexible enough to accommodate the availability of key Competent Authority personnel and yet ensure it met timeline commitments to the industry.

The Competent Authority worked with Deloitte on the interpretation of the standards and training for Financial Institutions. Vizor supported this with both in-person and online training.

Financial Institutions with low volumes of filings now have the option to use intuitive web forms and are not required to prepare XML files.

The Bahamas met its first time CRS reporting obligation forautomatic exchange of information by the September 30th deadline. Successful transmission of high-quality data was completed with its 35 partner jurisdictions. FATCA submissions were also successfully completed using the same integrated AEOI solution. The Competent Authority team are now able to handle exchanges on their own, without the need for technical support.

The AEOI team were delighted with the level of automation.In the older system, there was a need for manual conversion of files which meant some intermediate responsibility for the quality of the data. The new system ensures all validation is done as part of the submission process and conversion happens automatically, without any need for manual intervention.Similarly, process changes have made registration more streamlined and efficient.

The system provides filing summary information that greatly assists the Competent Authority with compliance tracking.It allows staff to review all entities that are registered and those where a reporting has been completed. Similar summary information is also available to Financial Institutions to support their internal controls.

Previously, The Bahamas was the only Competent Authority to use its technical platform. The Bahamas can now benefit from being part of a Vizor user community that includes 15+jurisdictions. They can draw on Vizor’s experience and make direct connections with other Competent Authority users as needed. As with any standard, there are always questions around practical implementation scenarios. When these are addressed for one user, they can be shared with the community as needed.