The software will create separate XML files for each jurisdiction of the Account Holder's Residential Country Code where the Reporting FI is setup with Cayman Islands (KY) as the Receiving Country, Transmitting Country, and ResCountry (shown below).

For instance, if a single Reporting FI from the Cayman Islands contains four accounts, two for Canada (CA) and the other two for China (CN), then two XML files would be generated.  The first file would contain only accounts where the Account Holder Residential Country Codes are for Canada (CA) and the second file would only contain accounts where the Account Holder Residential Country Codes are for China (CN).  This is different than the standard OECD XML format which would have all four accounts in a single file.

In each XML file the <crs:ReportingFI> would have <crs:ResCountryCode>KY</crs:ResCountryCode>

And the <crs:MessageSpec> would show KY as the Transmitting Country with CA or CN being the Receiving Country.  The software does not make any adjustments for Controlling Persons.


In addition to splitting the XML per jurisdiction, the application will create the XML so Passive Non-Financial Entity accounts with Controlling Persons, Account Holder Type CRS101, are reported only with respect to the Controlling Person.