Yes, there is a difference in due diligence procedures for individual vs. non-individual account holders under Samoa’s CRS Guideline and the OECD Standard. Each type follows distinct review and documentation rules. 

For Individual Account Holders

Self-certification required: Must provide tax residency, TIN, and date of birth.

Account classification:

  • Lower Value Accounts (< USD 1 million): Simplified review.
  • High Value Accounts (≥ USD 1 million): Enhanced review, including relationship manager inquiry.

Indicia check: RFIs must look for signs of foreign tax residency (e.g., foreign address, phone number, or power of attorney).

Undocumented accounts: If residency cannot be confirmed, the account may still be reportable.

 Non-Individual Account Holders (Entities)

Entity classification:

  • Determine if the entity is a Financial Institution, Active NFE, or Passive NFE.

Self-certification required: Must declare entity type and tax residency.

Controlling Persons:

  • If the entity is a Passive NFE, RFIs must identify and report individuals who control the entity.
  • These persons must also provide self-certification.