Changes to RA data collection | National reporting (Virati)
The FIN-FSA will add account information service providers to the list of reporting groups of the RA data collection as of 1 January 2023. A notice of reporting obligation has been sent to the companies separately.
The RA data collection will also have new questions as well as some smaller changes and revisions (will be announced later in the reporting releases). Changes that require actions from all reporters are the following:
Update of questions concerning due diligence information:
Questions to be removed:
- 790: What percentage of high-risk customers' due diligence information was updated during the reporting year?
- 800: What percentage of normal-risk customers' due diligence information was updated during the reporting year or the preceding year?
New questions:
- Number of high-risk customers whose due diligence information was not updated during the reporting year.
- Report the number of private customers classified into the high-risk category by the reporter and whose due diligence information was not updated during the reporting year. Updating means measures taken to ensure that customer information is up to date and relevant.
- Number of customers whose due diligence information was not updated during the reporting year or the preceding five years (including all risk categories).
- Report the number of private customers whose due diligence information was not updated during the reporting year or the preceding five years. Updating means measures taken to ensure that customer information is up to date and relevant.
- Number of high-risk customers whose due diligence information was not updated during the reporting year
- Report the number of corporate and institutional customers classified into the high-risk category by the reporter and whose due diligence information was not updated during the reporting year. Updating means measures taken to ensure that customer information is up to date and relevant.
- Number of customers whose due diligence information was not updated during the reporting year or the preceding five years (including all risk categories).
- Report the number of corporate and institutional customers whose due diligence information was not updated during the reporting year or the preceding five years. Updating means measures taken to ensure that customer information is up to date and relevant.
Residency for tax purposes / domicile / main location of business:
The questions (120, 125, 130, 132, 134, 136, 240, 250, 252, 254) have been aligned with the terminology applied by the tax authority, and an alternative has been added for cases where the reporter is not under FATCA/CRS and DAC2 reporting obligations. There is a new question for all reporters on corporate and institutional customers’ residency for tax purposes in Finland. All questions below for money remitters are new.
- Number of customers whose residency for tax purposes is Finland / permanent address is in Finland
- Report the number of private customers whose residency for tax purposes is Finland. Tax residency (residencies) is examined as part of the fulfilment of obligations concerning the exchange of information under international tax treaties (FATCA/CRS and DAC2). If the respondent is not under the reporting obligation for the exchange of information referred to above, it shall report the number of private customers with permanent address in Finland.
- Number of customers with residency for tax purposes / permanent address in the EU/EAA (excl. Finland)
- Report the number of private customers whose residency for tax purposes is within the EU/EAA (excl. Finland). Tax residency (residencies) is examined as part of the fulfilment of obligations concerning the exchange of information under international tax treaties (FATCA/CRS and DAC2). If the respondent is not under the reporting obligation for the exchange of information referred to above, it shall report the number of private customers with permanent address in the EU/EAA (excl. Finland).
- Number of customers with residency for tax purposes / permanent address outside the EU/EAA
- Report the number of private customers whose residency for tax purposes is outside the EU/EEA. Tax residency (residencies) is examined as part of the fulfilment of obligations concerning the exchange of information under international tax treaties (FATCA/CRS and DAC2). If the respondent is not under the reporting obligation for the exchange of information referred to above, it shall report the number of private customers with permanent address outside the EU/EAA.
- Customers whose residency for tax purposes / domicile / address of the main location of business is in Finland
- Report the number of corporate and institutional customers whose residency for tax purposes is Finland. Tax residency (residencies) is examined as part of the fulfilment of obligations concerning the exchange of information under international tax treaties (FATCA/CRS and DAC2). If the respondent is not under the reporting obligation for the exchange of information referred to above, it shall report the number of corporate and institutional customers whose domicile and/or address of the main location of business under chapter 3, section 3(2)(3) of the AML Act is in Finland.
- Customers whose residency for tax purposes / domicile / address of the main location of business is in EU/EAA (excl. Finland).
- Report the number of corporate and institutional customers whose residency for tax purposes is within the EU/EAA (excl. Finland). Tax residency (residencies) is examined as part of the fulfilment of obligations concerning the exchange of information under international tax treaties (FATCA/CRS and DAC2). If the respondent is not under the reporting obligation for the exchange of information referred to above, it shall report the number of corporate and institutional customers whose domicile and/or address of the main location of business under chapter 3, section 3(2)(3) of the AML Act is within the EU/EEA (excl. Finland).
- Customers whose residency for tax purposes / domicile / address of the main location of business is outside the EU/EEA.
- Report the number of corporate and institutional customers whose residency for tax purposes is outside the EU/EAA. Tax residency (residencies) is examined as part of the fulfilment of obligations concerning the exchange of information under international tax treaties (FATCA/CRS and DAC2). If the respondent is not under the reporting obligation for the exchange of information referred to above, it shall report the number of corporate and institutional customers whose domicile and/or address of the main location of business under chapter 3, section 3(2)(3) of the AML Act is outside the EU/EEA.
There will be a separate announcement in the FIN-FSA’s reporting releases in November when the new RA data collection and instructions have been released. The reference date of data collected is 31 December 2022. The reporting deadline is 28 February 2023.
For further information, please contact
- Technical issues and matters of interpretation relating to Virati reporting:
VIRATIhelpdesk(at)fiva.fi - Questions relating to the content of the report:
ulla-maija.kaivola(at)fiva.fi
Further information on the FIN-FSA website