Concept: Preexisting vs. New Accounts

Due diligence procedures under the CRS and FATCA depend heavily on when a financial account was opened. The regulations draw a sharp distinction between Preexisting Accounts and New Accounts, establishing different thresholds and timelines for their review.

Preexisting Accounts

A Preexisting Account is a financial account maintained by a Reporting Financial Institution (RFI) as of 31 December 2015 (for the original CRS) or the day before an entity becomes an FI.

Due Diligence Categories

Preexisting accounts are split into different categories, each with distinct review rules:

1. Individual Lower Value Accounts: Accounts held by individuals with an aggregate balance or value as of 31 December 2015 that does not exceed $1,000,000.
   • Procedure: RFIs can perform a simple electronic record search for foreign residency indicia.
2. Individual High Value Accounts: Accounts held by individuals with an aggregate balance or value exceeding $1,000,000 as of 31 December 2015 (or any subsequent year).
   • Procedure: RFIs must perform both electronic and paper searches, as well as a Relationship Manager inquiry.
3. Entity Accounts: Preexisting accounts held by entities.
   • Threshold: RFIs are exempt from reviewing preexisting entity accounts with an aggregate balance or value that does not exceed $250,000 as of 31 December 2015, until the balance exceeds $250,000 on the last day of any subsequent year.

New Accounts

A New Account is a financial account opened on or after 1 January 2016 (or the date an entity becomes an FI).

Due Diligence Rules

• Mandatory Self-Certification: RFIs must obtain a valid Self-Certification from the account holder upon account opening.
• No Thresholds: Unlike preexisting entity accounts, there is no $250,000 de minimis threshold for new entity accounts; all new accounts must be documented, regardless of balance.
• Remediation: If a self-certification is not obtained at onboarding, the account must be restricted or reported as an Undocumented Account.

Referenced PDF Sources

• OECD Consolidated Text of the Common Reporting Standard (2025)
• Tax Information Authority CRS Regulations (2021 Revision)
• OECD CRS Implementation Handbook (Second Edition)
• OECD Crypto-Asset Reporting Framework (CARF) & 2023 CRS Update
• OECD Standard for Automatic Exchange of Financial Account Information (Second Edition)
• The Amended Common Reporting Standard for Automatic Exchange of Financial Account Information in Tax Matters
• CRS Reporting Obligations: Date of Birth (DOB)
• CRS Reporting Obligations: Tax Identification Numbers (TINs)
• Cayman Islands MCAA (Certified Copy)
• Tax Information Authority ( International Tax Compliance) (Common Reporting Standard) (Amendment) Regulations, 2025
• CRS Undocumented Accounts: Explanatory Note
• CRS-related Frequently Asked Questions
• OECD CRS XML Schema User Guide
• DITC CRS Guidelines