Checklist: regularising a relationship inherited from the era of banking secrecy
- Verify the tax compliance of the client’s assets in every country in which the client is or has been a taxpayer, and document the evidence obtained.
- Identify any indicia of US tax status and apply the corresponding FATCA procedures.
- Ensure that the information required under the automatic exchange of information is collected and transmitted correctly.
- Examine the history of fund flows, in particular transfers to other institutions and large withdrawals in cash or precious metals.
- Document the decision to maintain or terminate the relationship, together with the conditions under which the assets leave the institution.
- Assess the residual criminal and reputational risks for the institution and for the staff concerned.
For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of September 2025.