CMA Circular of 2022 · UAE Federal
Explains how reporting financial institutions should report undocumented accounts under the Common Reporting Standard, limited to individual accounts opened before 1 January 2017.
This CMA circular explains how UAE Reporting Financial Institutions in the securities sector must identify and report "undocumented accounts" under the Common Reporting Standard (CRS). These are pre-existing individual accounts opened before 1 January 2017 for which the only indication of foreign tax residence is a hold-mail or in-care-of address and no self-certification or documentary evidence can be obtained. They must be flagged and reported every year.
The circular recalls that the CRS is the OECD standard for automatic exchange of financial account information. The UAE signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, the Multilateral Competent Authority Agreement and the Unilateral Declaration in April 2017. Under that framework, Reporting Financial Institutions collect and report account information annually, and it is exchanged with partner jurisdictions to identify account holders' and controlling persons' tax residence.
An account is undocumented where the institution holds a pre-existing individual account showing only a hold-mail or in-care-of address in a reportable jurisdiction, finds no other CRS indicia in its electronic and paper record searches, and cannot obtain a self-certification or documentary evidence from the account holder. For high-value pre-existing individual accounts, the institution must keep applying the undocumented account procedures until the status ends. That means an annual paper record search and continued efforts to obtain documentary evidence or a valid self-certification.
Undocumented accounts are reported in the relevant annual cycle using the flag in the CRS reporting template on the portal (TRUE for undocumented, FALSE otherwise). An account qualifies only if opened before 1 January 2017, and only an individual's account can be undocumented, never an entity's. The circular is guidance: it states that domestic CRS legislation takes precedence over it, and it imposes no penalties of its own.
UAE Reporting Financial Institutions under the Common Reporting Standard supervised by the Capital Market Authority, such as brokers, custodians and investment managers, that maintain pre-existing individual accounts opened before 1 January 2017.
English official text in 2 passages. Open the full text or jump to a provision:
| Section – Background to the CRS | The UAE signed the Multilateral Convention, the MCAA and the Unilateral Declaration in April 2017; Reporting Financial Institutions collect and report account information annually for exchange with partner jurisdictions. |
| Section – Impact of the CRS | Defines an undocumented account: a pre-existing individual account with only a hold-mail or in-care-of address in a reportable jurisdiction, no other indicia, and no obtainable self-certification or documentary evidence. |
| Section – Impact of the CRS (procedures) | For high-value pre-existing individual accounts, institutions must keep applying undocumented account procedures, including an annual paper record search and continued efforts to obtain evidence, until the status ends. |
| Section – Reporting | Undocumented accounts are reported in the annual cycle using the template flag TRUE, with FALSE for other accounts; only accounts opened before 1 January 2017 and held by individuals qualify. |
Polaris is not a Reporting Financial Institution for these purposes and does not file CRS returns for regulated firms. The circular explains why brokers and custodians keep asking our clients, and the individuals behind them, for CRS self-certifications and tax residence evidence. For the holding companies and individuals we serve, we help keep tax residence certificates, addresses and TINs current and consistent across the corporate record, so that clients can answer self-certification requests promptly and avoid their accounts being flagged and reported as undocumented.
No amendments, repeals or cross-references recorded for this instrument.
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