Enhanced Monitoring Report on the Implementation of the Standard on Transparency and Exchange of Information on Request 2026 Update (June)

Saint Kitts and Nevis

(Adopted by the Global Forum in June 2026)

Saint Kitts and Nevis joined the Global Forum in 2009. Saint Kitts and Nevis underwent its Second Round of EOIR Peer Review in 2018 (Saint Kitts and Nevis’ 2018 Report),1 which assessed its legal and regulatory framework in force as of 31 July 2018 and its practical implementation, including in respect of EOI requests received and sent during the review period from 1 July 2014 to 30 June 2017. Saint Kitts and Nevis received an overall rating of Largely Compliant and the individual Elements were rated as follows:

 

	A.1	A.2	A.3	B.1	B.2	C.1	C.2	C.3	C.4	C.5	Overall
Determinations	i.p.	i.p.	i.p.	i.p.	i.p.	i.p.	i.p.	i.p.	i.p.	n.a.	LC
Ratings	LC	LC	C	C	C	C	C	C	C	C

Status of implementation of recommendations issued in the peer review report

Saint Kitts and Nevis received five in-box recommendations in relation to Elements A.1, A.2, A.3 and B.1.

This monitoring report assesses the actions taken by Saint Kitts and Nevis to address the recommendations issued in its EOIR Peer Review Report and the peer input received for the monitoring period 2023-2024.

The report concludes that four recommendations are “in the process of being addressed”, one recommendation pertaining to Element A.3 is “considered provisionally addressed in the context of the monitoring process, subject to detailed validation”, issues a new corresponding recommendation to monitor the implementation of the legislative changes introduced on Element A.3, and advises on actions required.

Element A.1: Availability of ownership and identity information

1. Availability of beneficial ownership information of partnerships

 

Recommendation (A.1, framework)	Saint Kitts and Nevis should ensure that information on all beneficial owners of a partnership is available in line with the standard in all cases.
Underlying factor	A partnership, that is not a regulated business or has not engaged a licensed service provider, must provide ownership information to the tax administration and/or the Registrar; however, a natural or legal person may be identified as a general partner and there is no obligation to identify a limited partner. Also, there is no requirement under the AML/CFT laws to verify the identity of a limited partner of a partnership that is a regulated business or has engaged a licensed service provider. Therefore, the ownership information available may not necessarily identify all beneficial owners of a partnership in line with the standard. (see paragraphs 147 to 171 of the Saint Kitts and Nevis’ 2018 Report for more information)
Summary of actions reported	In 2019, the Limited Partnerships Act was amended to require the submission of information that identifies any natural person who has beneficial ownership interest in a limited partnership. Additionally, in 2020, the Financial Services (Implementation of Industry Standards) Regulations were amended to require that limited partners should also be subject to verification for customer due diligence purposes. Further, in 2024 the Limited Partnerships Act was amended to require limited partnerships to submit a copy of the partnership agreement to the Registrar, at the time of registration. The partnership agreement must include among other things, the general and limited partners involved in the partnership, controlling powers of the partners and voting rights. Changes to such information must be reported within 21 days. There are eight limited partnerships registered in Saint Kitts and the office of the Registrar has undertaken the necessary actions to obtain the relevant identifying particulars for all natural persons with beneficial ownership interests for these limited partnerships.
Conclusion	Saint Kitts and Nevis has made progress to address the recommendation. The amendments to the Financial Services (Implementation of Industry Standards) Regulations now require that all limited partners be subject to verification, in addition to general partners. Therefore, the beneficial owners of a limited partnership are required to be identified pursuant to customer due diligence obligations. Additionally, the amendments to the Limited Partnerships Act require the identification and submission of information on any natural person who has beneficial ownership interest in the partnership and require the submission of copies of partnership agreements to the Registrar. Although these amendments have improved the legal and regulatory framework that requires the availability of beneficial ownership information, there are still gaps. Firstly, regarding the AML framework, there is no obligation for all general partnerships to engage an AML‑obliged person in an ongoing business relationship. Secondly, the Limited Partnerships Act does not define or provide guidance on what constitutes “beneficial ownership interest” although, having regard to the nature of limited partnerships, the requirement to identify all natural persons may lead to identification of some beneficial owners. While the Registrar has undertaken actions to obtain the relevant identifying particulars for all natural persons with beneficial ownership interests for the limited partnerships registered on the Commercial Registry, Saint Kitts and Nevis has not reported any implementation details of these actions, including how the submitted information is verified for accuracy and adequacy and how it is kept up to date. Moreover, no implementation details have been provided regarding the availability of beneficial ownership information of general partnerships or how the changes to the financial industry regulations that require that limited partners in a limited partnership should also be subject to verification for customer due diligence purposes , have been enforced. Saint Kitts and Nevis should report further progress in its next self-assessment.
Status determined	In the process of being addressed
Actions required	In its next self-assessment in [2028], Saint Kitts and Nevis should – Report on further actions taken to ensure that the legal and regulatory framework requires the availability of adequate, accurate and up-to-date beneficial ownership information on all relevant partnerships. Report on further updates on the actions taken to implement relevant measures in the AML laws and Limited Partnerships Act, and supervisory actions taken to ensure availability of adequate, accurate and up-to-date beneficial ownership information of all relevant partnerships. Report on the follow-up on non-compliance with the obligations related to identification of beneficial owners and the pursuant sanctions issued, if any.

2. Monitoring the implementation of legal and beneficial ownership requirements for companies and partnerships

 

Recommendation (A.1, practice)	Saint Kitts and Nevis should take further measures to ensure that legal and beneficial ownership information in respect of ordinary and domestic companies and information identifying the partners in, and the beneficial owners of, partnerships is practically available as required under the standard.
Underlying factor	Legal and beneficial ownership information in respect of ordinary and domestic companies, as well as information identifying the general partners (natural persons) of partnerships, is available if the entity is a regulated business or the entity engages a licensed service provider. Legal and beneficial ownership information on ordinary and domestic companies and information identifying the general partners (natural or legal persons) of LPs [Limited Partnerships] should also be available with the Registrars; however, not all companies comply with the obligation to file annual returns. In addition, the low compliance rate with tax filing obligations for companies and the small proportion of partnerships audited by the tax administration do not ensure that ownership information is available as required under the law in all cases. (see paragraphs 130 et seq. of Saint Kitts and Nevis’ 2018 Report for more information)
Summary of actions reported	In 2019, the Limited Partnerships Act was amended to require the submission to the Registrar of information that identifies any natural person who has beneficial ownership interest in a limited partnership. Further, since 2024, limited partnerships must submit a copy of the partnership agreement to the Registrar, at the time of registration, and changes to such information must be reported within 21 days. All the limited partnerships have submitted their partnership agreements, and the office of the Registrar has undertaken the necessary actions to obtain the relevant identifying particulars for all natural persons with beneficial ownership interests for the limited partnerships registered on the Commercial Registry. Additionally, upon incorporation or registration, legal and beneficial ownership information for all entities conducting business in the territory, including for ordinary and domestic companies, and for limited and general partnerships are provided to the Inland Revenue Department. All entities are required to notify the tax administration of any changes to their legal and beneficial ownership information within seven days of the change. The Inland Revenue Department also confirms ownership information while conducting all tax audits and compliance procedures. In addition, the Registrar has provided the Inland Revenue Department with legal and beneficial ownership information for all domestic and ordinary companies and limited partnerships as available on the Commercial Registry.
Conclusion	Saint Kitts and Nevis has made progress to address the recommendation. Legislative changes in the Saint Kitts Companies Act and the Limited Partnerships Act require beneficial ownership information to be submitted to the Registrar. These obligations ease the supervision of the authorities and complement related obligations on general partnerships, and domestic and ordinary companies to provide legal ownership information to the Registrar. Saint Kitts and Nevis reported that through these obligations, all domestic and ordinary companies and partnerships have submitted their identity, legal and beneficial ownership information to the Registrar. In turn, the Registrar has provided all the information to the Inland Revenue Department. Additionally, at the time of incorporation or registration, domestic and ordinary companies and partnerships are required to submit legal ownership and beneficial ownership information to the Inland Revenue Department and update such information within seven days of any change and also through annual filing. This information is verified during audit and tax compliance activities. While these actions are noted, no further details have been provided regarding the outcomes of actual implementation, such as the compliance rate of filing of annual returns or number of audits conducted by the Inland Revenue Department or sanctions issued, if any. Moreover, regarding beneficial ownership information on the entities, it is not demonstrated whether the submitted information is accurate, adequate and up to date, since there are deficiencies in the definition of beneficial owner contained in the Companies Act and the Limited Partnerships Act. Saint Kitts and Nevis should report further progress in its next self-assessment.
Status determined	In the process of being addressed
Actions required	In its next self-assessment in 2028, Saint Kitts and Nevis should – Report on further supervisory actions undertaken, and their outcomes, to ensure compliance of all partnerships and domestic and ordinary companies, with AML, commercial and tax reporting obligations that support the availability of legal and beneficial ownership information. Report on the details of AML supervision, tax audit and other regulatory compliance activities, including statistical information on the activities conducted and related outcomes and sanctions issued, if any.

Element A.2: Availability of accounting information

3. Enhancing the supervision and enforcement of obligations on accounting records

 

Recommendation (A.2, practice)	Saint Kitts and Nevis should take further supervisory measures and exercise enforcement measures, including against relevant legal entities and arrangements, to ensure the availability of accounting information in all cases as required under the standard.
Underlying factor	Although Saint Kitts and Nevis authorities carry out supervisory measures focused on the availability of accounting information, these do not result in sufficient levels of compliance to ensure that the relevant accounting information (including underlying documentation) is available in all cases. Further, while enforcement measures have been taken against licensed service providers, no penalties have been directly applied to relevant legal entities or arrangements to ensure the availability of accounting information in all cases. (see paragraphs 250 et seq. of the Saint Kitts and Nevis’ 2018 Report for more information)
Summary of actions reported	The Registrar collects and maintains relevant accounting information through the submission of audited financial statements as part of the annual return or solvency statements for domestic entities. Additionally, entities seeking certificates of good standing must submit audited financial statements. For the period 2022 and 2023, an average of 76% of domestic companies registered in Saint Kitts submitted financial statements to the Registrar annually. With respect to offshore entities, there was a decreased level of examinations being performed due to pandemic related restrictions. There were six on-site examinations conducted on service providers. In five instances, accounting records or signed statements confirming dormancy due to lack of business activities/transactions were made available. For the remaining case, following the non-receipt of the requested accounting records, the relevant entity was struck off from the register. Additionally, two follow-up examinations were also conducted to evaluate the progress of addressing the deficiencies noted during previous full-scope on-site examinations. It was observed that the deficiencies had since been rectified, and the accounting records were made available in both instances. Following a change in company regimes from exempt companies (offshore sector entities registered under the Saint Kitts Companies Act) to international companies that are also fully offshore, 1 143 exempt companies that did not transition to the new regime have been struck off and dissolved.
Conclusion	Some submissions of accounting records of domestic entities subject to annual filing requirements to the Registrar under Saint Kitts laws, were reported. However, the compliance rate has not improved, in comparison to the peer review report. Some non-complying domestic companies were struck off and dissolved, but akin to the conclusion in the 2018 Report, this sanction did not improve compliance or availability of accounting records. Moreover, Saint Kitts and Nevis did not provide information on compliance rates with tax filing, tax audits, or other measures to ensure that these domestic entities maintain proper accounting records. Additionally, no information on the compliance of entities registered under Nevis laws, has been provided. Regarding entities in the offshore sector, the number of inspections reported, compared to the peer review report, is lower and although the decline was attributed to pandemic-related restrictions, there is no reported increase after the pandemic. Regarding the outcomes of the inspections, in two cases, deficiencies were resolved by submitting accounting records while in one case, an entity was struck off for non-compliance, although this action does not guarantee availability of its accounting records. Further, concerning former exempt companies that did not transition into different regimes owing to the changes in the Saint Kitts Companies Act (that has now provided for creation of international companies) and were struck off, it is not ascertained whether the accounting records of such entities are maintained for at least five years as required by the standard. Saint Kitts and Nevis has made some progress to address the recommendation. The steps taken do not sufficiently demonstrate material progress despite the elapse of more than three years since the last peer review. Hence, Saint Kitts and Nevis should submit a schedule for completion of steps to address the recommendation and an update on its progress made to address the recommendation by 31 March 2027.
Status determined	In the process of being addressed
Actions required	Saint Kitts and Nevis should submit a schedule for completion of steps to address the recommendation and an update on its progress made to address the recommendation by 31 March 2027. In particular, Saint Kitts and Nevis should – Provide details of the supervisory activities and enforcement actions of the supervisory authorities, including the tax authorities, the Registrar and the Financial Services Regulatory Commission, to ensure availability of accounting records and underlying documents of domestic and non-domestic entities and arrangements. Report on actions taken to ensure that the accounting records of formerly exempt entities under the pre 2021 regime of the Companies Act of Saint Kitts are available in line with the standard, especially in cases where the records of such entities were kept at a place(s) outside of Saint Kitts and Nevis. Report material progress on addressing the recommendation to ensure that accounting records and underlying documentation of all entities and arrangements are available in line with the standard.

Element A.3 Availability of banking information

4. Availability of beneficial ownership on bank accounts of limited partnerships

 

Recommendation (A.3, framework)	Saint Kitts and Nevis should ensure that banks are required to identify all of the beneficial owners of a LP [Limited Partnership] as required under the standard.
Underlying factor	While banks are required to verify the identity of general partners of a LP [Limited Partnership] in line with the standard, there is no requirement to verify the identity of limited partners. Limited partners may be relevant for the identification of beneficial owners as defined under the standard. (see paragraphs 279 et seq. of Saint Kitts and Nevis’ 2018 Report for more information)
Summary of actions reported	The Financial Services (Implementation of Industry Standards) Regulations were amended in 2020, to require that both general partners and limited partners be verified as part of the customer due diligence process.
Conclusion	Saint Kitts and Nevis appears to have taken appropriate actions to address the legal issue by amending the Financial Services (Implementation of Industry Standards) Regulations to require that all beneficial owners of bank accounts operated by limited partnerships, are identified in line with the standard. Saint Kitts and Nevis is expected to report progress on the implementation and enforcement of these changes under a new recommendation. Saint Kitts and Nevis is recommended to monitor the effective implementation and enforcement of the amended regulation to ensure that adequate, accurate and up-to-date beneficial ownership information is available for bank accounts of limited partnerships in line with the standard.
Status determined	Existing recommendation: Considered provisionally addressed in the context of the monitoring process, subject to detailed validation. New recommendation issued.
Actions required	Existing recommendation: No immediate action required. In its next self-assessment in 2028, Saint Kitts and Nevis should – Report progress on the implementation and enforcement of the changes in the legal and regulatory framework, under the new recommendation, including reporting the details of supervisory and enforcement activities on banks, statistical information on number of activities conducted and related outcomes and sanctions issued, if any.

Element B.1: Access to information

5. Using the competent authority’s access powers effectively

 

Recommendation (B.1, practice)	Saint Kitts and Nevis should ensure that its powers to obtain information are used effectively so that the requested information can be provided in a timely manner
Underlying factor	Saint Kitts and Nevis has powers in place to obtain all types of information but did not effectively exercise these powers in the one case where it was necessary in order to obtain information from an information holder. (see paragraphs 312 et seq. of Saint Kitts and Nevis’ 2018 Report for more information)
Summary of actions reported	The competent authority continued to use its access powers to effectively gather information that was requested. With respect to the one pending request for which the competent authority sought a Court order, the competent authority was able to obtain and exchange some of the information from another source. As the requesting jurisdiction subsequently withdrew its request for any outstanding information, the process for obtaining the Court order was discontinued.
Conclusion	Saint Kitts and Nevis has made progress in addressing the recommendation. Where there have been delays in obtaining the requested information, some cases have been forwarded for legal action. The decision to forward the cases was taken in 2025, and it is not yet ascertained whether the planned actions will compel the information holder to provide the requested information. Saint Kitts and Nevis should report further progress in its next self-assessment.
Status determined	In the process of being addressed
Actions required	In its next self-assessment in 2028, Saint Kitts and Nevis should – Report on the progress of legal action taken to compel information holders to provide requested information in a timely manner. Report on any other sanctions applied as part of exercising the powers of the competent authority for accessing information requested for EOIR purposes, especially where there are delays in providing the requested information.

EOIR experience

Over the monitoring period, Saint Kitts and Nevis received 15 requests and did not send any requests. Spain, Argentina and the United Kingdom were the top three partners in respect of incoming requests. Saint Kitts and Nevis reported providing full and final responses in 80% of all the received requests and indicated 20% (3 requests) as pending requests. The pending requests were received in 2024.

Four peers provided peer input on their EOIR relationship with Saint Kitts and Nevis. Peers were generally satisfied, with two out of the four peers confirming that they sent requests and received responses from Saint Kitts and Nevis, while the other two mentioned that the relationship was untested.

New developments having a bearing on the EOIR standard

No recent developments that have a bearing on the EOIR standard (other than those reported to address recommendations) have been reported by Saint Kitts and Nevis or have otherwise come to light.

Next steps

Saint Kitts and Nevis should continue taking actions towards implementing the standard effectively.

Under the first round of enhanced monitoring, a new recommendation has been issued to Saint Kitts and Nevis.

6. Monitoring the implementation of beneficial ownership requirements for bank accounts of limited partnerships

 

Recommendation (A.3, practice)	Saint Kitts and Nevis is recommended to monitor the effective implementation and enforcement of the amended regulation to ensure that adequate, accurate and up-to-date beneficial ownership information is available for bank accounts of limited partnerships in line with the standard.
Underlying factor	Saint Kitts and Nevis amended the Financial Services (Implementation of Industry Standards) Regulations to remove an earlier limitation on identifying limited partners as beneficial owners of bank accounts held by limited partnerships. The implementation in practice of these legislative amendments is yet to be ascertained.

The following next steps are expected from Saint Kitts and Nevis:

• For recommendation 3 on Enhancing the supervision and enforcement of obligations on accounting records (Element A.2), where lack of material progress has been identified for more than three years since the last review, Saint Kitts and Nevis should submit to the PRMG - i) a schedule for completion of steps to address the recommendation and ii) an update, including details on the progress on such recommendations by 31 March 2027.

• Submit the next self-assessment, including on the new recommendations issued, in 2028 under the second round of enhanced monitoring.

• See also Chapter 1 (Scope and Methodology), section on “PRMG decisions – Statuses determined and actions required”, which explains the next steps expected on recommendations that are “considered provisionally addressed in the context of the monitoring process, subject to detailed validation”.

Views/response of the monitored jurisdiction

The Federation of Saint Kitts and Nevis reaffirms its commitment to the Global Forum on Transparency and Exchange of Information for Tax Purposes. We express our sincere appreciation to the Global Forum Secretariat for its continued support, guidance and engagement throughout the Enhanced Monitoring process. We also thank the members of the Peer Review and Monitoring Group, along with all partners, for their valuable contributions and collaboration.

Saint Kitts and Nevis appreciates the recognition of the significant improvements made to its legislative and supervisory frameworks and acknowledges the recommendations provided to address the identified gaps. The Federation remains dedicated to further strengthening its systems and practices to ensure the sustained effectiveness of the exchange of information on request.

Note

← 1.  OECD (2018), Global Forum on Transparency and Exchange of Information for Tax Purposes: Saint Kitts and Nevis 2018 (Second Round): Peer Review Report on the Exchange of Information on Request, Global Forum on Transparency and Exchange of Information for Tax Purposes, OECD Publishing, Paris, https://doi.org/10.1787/9789264306141-en.