20/11/2018 – As part of its efforts to maintain the integrity of the Common Reporting Standard (CRS), the OECD has been working closely with Panama over the last weeks to ensure that any risks created by its Residence by Investment (RBI) programmes are effectively addressed. As a result of that work, we are pleased to provide further clarity in relation to Panama’s Reforestation Investor Permit, Economic Solvency Permit and Friendly Nations Permit programmes. Importantly, under each of these programs, Panama ensures that residence documentation provided to successful applicants is identified as issued under the relevant programme.
The OECD has therefore updated* its guidance for financial institutions on CBI/RBI schemes to state that, where residence documentation clearly identifies the programme under which it was issued, only such specific residence documentation, should be perceived as potentially high-risk in the context of the CRS due diligence procedures. When presented with such documentation, financial institutions may consider applying the enhanced CRS due diligence procedures, in order to ensure that the documentation is not misused by account holders for the purpose of circumventing the CRS. In other cases, Panama-issued residency documentation is not by itself to be treated as being potentially high-risk from the perspective of the CRS due diligence procedures.
The OECD guidance will be updated on an ongoing basis where other jurisdictions adopt effective mitigating measures.