Due Diligence Procedures. Non-publicly traded CIS Are fund managers responsible for the CRS due diligence and reporting obligations for non-publicly traded CIS under the CRS? The due diligence and reporting obligations for non-publicly traded CIS under both CRS and FATCA fall on the fund manager. For non-publicly traded ▇▇▇, given that the fund manager is responsible for performing AML/CFT due diligence and on- boarding of the investor, the fund manager shall similarly be responsible for complying with the obligations under the CRS. Where the fund manager is not based in Singapore and the CIS is a trust, the local trustee shall be responsible for complying with the obligations under the CRS. The fund manager or trustee may appoint a third-party service provider to fulfil due diligence and reporting requirements, but the fund manager or trustee remains responsible for ensuring that these requirements are fulfilled.
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Sources: Faqs on the Common Reporting Standard, Faqs on the Common Reporting Standard
Due Diligence Procedures. Non-publicly traded CIS Are fund managers responsible for the CRS due diligence and reporting obligations for non-publicly traded CIS under the CRS? The due diligence and reporting obligations for non-publicly traded CIS under both CRS and FATCA fall on the fund manager. For non-publicly traded ▇▇▇CIS, given that the fund manager is responsible for performing AML/CFT due diligence and on- boarding of the investor, the fund manager shall similarly be responsible for complying with the obligations under the CRS. Where the fund manager is not based in Singapore and the CIS is a trust, the local trustee shall be responsible for complying with the obligations under the CRS. The fund manager or trustee may appoint a third-party service provider to fulfil due diligence and reporting requirements, but the fund manager or trustee remains responsible for ensuring that these requirements are fulfilled.
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