Peer Review of the Automatic Exchange of Financial Account Information 2024 Update

Peru

This report analyses the implementation of the AEOI Standard in Peru with respect to the requirements of the AEOI Terms of Reference. It assesses both the legal frameworks put in place to implement the AEOI Standard and the effectiveness of the implementation of the AEOI Standard in practice.

The methodology used for the peer reviews and that therefore underpins this report is outlined in Chapter 2.

Overall findings

AEOI legal framework

Peru’s legal framework implementing the AEOI Standard is in place but needs improvement in order to be fully consistent with the requirements of the AEOI Terms of Reference. While Peru’s international legal framework to exchange the information with all of Peru’s Interested Appropriate Partners (CR2) is consistent with the requirements, its domestic legislative framework requiring Reporting Financial Institutions to conduct the due diligence and reporting procedures (CR1) has deficiencies significant to the proper functioning of elements of the AEOI Standard. More specifically, deficiencies have been identified in relation to the scope of Reporting Financial Institutions and Financial Accounts and there are deficiencies in the enforcement framework.

Overall determination on the legal framework: In Place But Needs Improvement

Effectiveness of AEOI in practice

Peru’s implementation of the AEOI Standard is on track with respect to the requirements of the AEOI Terms of Reference to ensure the effectiveness of the AEOI Standard in practice. This includes ensuring Reporting Financial Institutions correctly conduct the due diligence and reporting procedures (CR1) and exchanging the information in an effective and timely manner (CR2). Peru is encouraged to continue its implementation process accordingly, to ensure its ongoing effectiveness.

Overall rating in relation to the effectiveness in practice: On Track

General context

Peru commenced exchanges under the AEOI Standard in 2020.

In order to provide for Reporting Financial Institutions to collect and report the information to be exchanged, Peru:

• relies on Article 87(7), Article 175(7 and 8) and Article 177(2, 3, 15, 27 and 28) of the Tax Code;

• relies on Articles 427 and 438 of the Criminal Code; and

• enacted Supreme Decree 256-2018-EF (Regulation establishing the financial information that shall be provided to SUNAT to conduct the automatic Exchange of information as set forth in international agreements and the Decisions of the Andean Community Commission).

Under this framework Reporting Financial Institutions were required to commence the due diligence procedures in relation to New Accounts from 1 January 2019. With respect to Preexisting Accounts, Reporting Financial Institutions were required to complete the due diligence procedures on High-Value Individual Accounts by 31 December 2019 and on Preexisting Lower Value Individual Accounts and Entity Accounts by 31 December 2020.

With respect to the exchange of the information under the AEOI Standard, Peru is a Party to the Convention on Mutual Administrative Assistance in Tax Matters and activated the associated CRS Multilateral Competent Authority Agreement in time for exchanges in 2020.

Table 1 sets out the number of Financial Institutions in Peru that reported information on Financial Accounts in 2023 as defined in the AEOI Standard (essentially because they maintained Financial Accounts for Account Holders, or relating to Controlling Persons, resident in a Reportable Jurisdiction). It also sets out the number of Financial Accounts that they reported in 2023. In this regard, it should be noted that Peru requires the reporting of Financial Accounts based on a prescribed list of exchange partners and some accounts may be required to be reported more than once (e.g. jointly held accounts or accounts with multiple related Controlling Persons), which is reflected in the figures below. These figures provide key contextual information to the development and implementation of Peru’s administrative compliance strategy, which is analysed in the subsequent sections of this report.

Table.7. Number of Financial Institutions reporting and Financial Accounts reported

	Number
Number of Financial Institutions reporting Financial Accounts in 2023	140
Number of Financial Accounts reported in 2023	22 750

Table 2 sets out the number of exchange partners to which information was successfully sent by Peru in the past few years (including where the necessary frameworks were in place, containing an obligation on Reporting Financial Institutions to report information, but no relevant Reportable Accounts were identified). These figures provide key contextual information in relation to Peru’s exchanges in practice, which is also analysed in subsequent sections of this report.

Table.8. Number of exchange partners to which information was successfully sent

 

	2021	2022	2023
Number of exchange partners to which information was successfully sent	45	61	73

In order to provide for the effective implementation of the AEOI Standard, in Peru:

• the Superintendencia Nacional de Aduanas y de Administración Tributaria (SUNAT, the tax authority) has the responsibility to ensure the effective implementation of the due diligence and reporting obligations by Reporting Financial Institutions and for exchanging the information with Peru’s exchange partners;

• technical solutions necessary to receive and validate the information reported by Reporting Financial Institutions were put in place through the Integral System of Reception and Automatic Exchange of Information, which is based on the Multiple Data Exchange Solution (MDES) and allows for validation of the data received from Reporting Financial Institutions; and

• the Common Transmission System (CTS) is used for the exchange of the information, along with the associated file preparation and encryption requirements.

It should be noted that the review of Peru’s legal frameworks implementing the AEOI Standard concluded with the determination that Peru’s domestic legal framework is In Place But Needs Improvement and its international legal framework is In Place. This has been taken into account when reviewing the effectiveness of Peru’s implementation of the AEOI Standard in practice and where particular identified gaps in Peru’s legal frameworks directly impact its implementation in practice, these are mentioned below.

Findings and conclusions on the legal frameworks

The detailed findings and conclusions on the AEOI legal frameworks for Peru are below, organised per Core Requirement (CR) and sub-requirement (SR), as extracted from the AEOI Terms of Reference (see Annex C).

CR1 Domestic legal framework: Jurisdictions should have a domestic legislative framework in place that requires all Reporting Financial Institutions to conduct the due diligence and reporting procedures in the CRS, and that provides for the effective implementation of the CRS as set out therein.

Determination: In Place But Needs Improvement

Peru’s domestic legislative framework is in place and contains most of the key aspects of the CRS and its Commentary requiring Reporting Financial Institutions to conduct the due diligence and reporting procedures, but it needs improvement in relation to the scope of Reporting Financial Institutions required to report information (SR 1.1), the scope of Financial Accounts required to be reported (SR 1.2) and the framework to enforce the requirements (SR 1.4). Most significantly, Peru’s legislative framework does not define Financial Institutions in accordance with the AEOI Standard nor does it contain rules to prevent practices intended to circumvent the reporting and due diligence procedures as required.

SR 1.1 Jurisdictions should define the scope of Reporting Financial Institutions consistently with the CRS.

Peru has defined the scope of Reporting Financial Institutions in its domestic legislative framework in a manner that is largely consistent with the CRS and its Commentary. However, a deficiency has been identified. More specifically, Peru has defined Financial Institutions with reference to entities described in other financial law, which will include entities that are not Financial Institutions under the AEOI Standard. The scope of Reporting Financial Institutions is material to the proper functioning of the AEOI Standard.

Recommendations:

Peru should amend its domestic legislative framework to ensure that the meaning of “Custodial Institution”, “Investment Entity” and “Specified Insurance Company” are defined in line with the AEOI Standard.

SR 1.2 Jurisdictions should define the scope of Financial Accounts and Reportable Accounts consistently with the CRS and incorporate the due diligence procedures to identify them.

Peru has defined the Financial Accounts that are required to be reported in its domestic legislative framework and incorporated the due diligence procedures that must be applied to identify them in a manner that is largely consistent with the CRS and its Commentary. However, deficiencies have been identified. More significantly, Peru’s legislative framework:

• does not limit the use of a mailing address when applying the residence address test only to the special circumstances as contemplated in the Commentary; and

• does not define annuity contracts in line with the AEOI Standard.

The scope of Financial Accounts and the due diligence procedures are material to the proper functioning of the AEOI Standard.

Recommendations:

Peru should amend its domestic legislative framework to ensure that a mailing address is only permitted to be used in the special circumstances permitted under the AEOI Standard.

Peru should amend its domestic legislative framework to ensure that the exclusion of retirement income contracts from the definition of annuity contract is in line with the AEOI Standard.

SR 1.3 Jurisdictions should incorporate the reporting requirements contained in Section I of the CRS into their domestic legislative framework.

Peru has incorporated the reporting requirements in its domestic legislative framework in accordance with the CRS and its Commentary.

Recommendations:

No recommendations made.

SR 1.4 Jurisdictions should have a legislative framework in place that allows for the enforcement of the requirements of the CRS in practice.

Peru has a legislative framework in place to enforce the requirements in a manner that is largely consistent with the CRS and its Commentary. However, deficiencies have been identified. More specifically, Peru’s legislative framework:

• does not include rules to prevent all relevant persons (including Reporting Financial Institutions, other persons and intermediaries) from adopting any practices intended to circumvent the reporting and due diligence procedures as required; and

• does not impose sanctions on Account Holders and Controlling Persons for the provision of a false self-certification.

These are the key elements of the required enforcement framework relates to and are therefore material to the proper functioning of the AEOI Standard.

Recommendations:

Peru should amend its domestic legislative framework to introduce rules to prevent Financial Institutions, persons and intermediaries from adopting practices intended to circumvent the due diligence and reporting procedures.

Peru should amend its domestic legislative framework to include sanctions on Account Holders and Controlling Persons for the provision of a false self-certification. 

CR2 International legal framework: Jurisdictions should have exchange relationships in effect with all Interested Appropriate Partners as committed to and that provide for the exchange of information in accordance with the Model CAA.

Determination: In Place

Peru’s international legal framework to exchange the information is in place, is consistent with the Model CAA and its Commentary and provides for exchange with all of Peru’s Interested Appropriate Partners (i.e. all jurisdictions that are interested in receiving information from Peru and that meet the required standard in relation to confidentiality and data safeguards) (SRs 2.1 – 2.3).

SR 2.1 Jurisdictions should have exchange agreements in effect with all Interested Appropriate Partners that permit the automatic exchange of CRS information.

Peru has exchange agreements that permit the automatic exchange of CRS information in effect with all its Interested Appropriate Partners.

Recommendations:

No recommendations made.

SR 2.2 Such an exchange agreement should be put in place without undue delay, following the receipt of an expression of interest from an Interested Appropriate Partner.

Peru put in place its exchange agreements without undue delay.

Recommendations:

No recommendations made.

SR 2.3 Jurisdictions should ensure that the exchange agreements in effect provide for the exchange of information in accordance with the requirements of the Model CAA.

Peru’s exchange agreements provide for the exchange of information in accordance with the requirements of the Model CAA.

Recommendations:

No recommendations made.

Assessed jurisdiction’s comments on the assessment of its legal frameworks

Please note that Peru has introduced amended Supreme Decree N° 256-2018-EF by means of Supreme Decree N° 139-2024-EF in order to remedy the deficiencies identified in the AEOI peer review related with sub requirements 1.1 and 1.2.

Findings and conclusions in relation to effectiveness in practice

The following table contains the detailed findings for Peru, organised per Core Requirement (CR) and then per sub-requirement (SR) as extracted from the AEOI Terms of Reference.

CR1 Effectiveness in practice: Jurisdictions should ensure that in practice Reporting Financial Institutions correctly implement the due diligence and reporting procedures, which includes a requirement for jurisdictions to have in place an administrative framework to ensure the effective implementation of the CRS.

Rating: On Track

Peru’s implementation of the AEOI Standard is on track with respect to ensuring that Reporting Financial Institutions are correctly conducting the due diligence and reporting procedures and are therefore reporting complete and accurate information. This includes ensuring effectiveness in a domestic context, such as through having an effective administrative compliance framework and related procedures (SR 1.5), and collaborating with exchange partners to ensure effectiveness (SR 1.6). Peru is encouraged to continue its implementation process to ensure its ongoing effectiveness.

SR 1.5 Jurisdictions should ensure that in practice Reporting Financial Institutions identify the Financial Accounts they maintain, identify the Reportable Accounts among those Financial Accounts, as well as their Account Holders, and where relevant Controlling Persons, by correctly conducting the due diligence procedures and collect and report the required information with respect to each Reportable Account. This includes having in place:

a) an effective administrative compliance framework to ensure the effective implementation of, and compliance with, the CRS. This framework should:

i. be based on a strategy that facilitates compliance by Reporting Financial Institutions and which is informed by a risk assessment in respect of the effective implementation of the CRS that takes into account relevant information sources (including third party sources);

ii. include procedures to ensure that Financial Institutions correctly apply the definitions of Reporting Financial Institutions and Non-Reporting Financial Institutions;

iii. include procedures to periodically verify Reporting Financial Institutions’ compliance, conducted by authorities that have adequate powers with respect to the reviewed Reporting Financial Institutions, with procedures to access the records they maintain; and

b) effective procedures to ensure that Financial Institutions, persons or intermediaries do not circumvent the due diligence and reporting procedures;

c) effective enforcement mechanisms to address non-compliance by Reporting Financial Institutions;

d) strong measures to ensure that valid self-certifications are always obtained for New Accounts;

e) effective procedures to ensure that each, or each type of, jurisdiction-specific Non-Reporting Financial Institution and Excluded Account continue to present a low risk of being used to evade tax; and

f) effective procedures to follow up with a Reporting Financial Institution when undocumented accounts are reported in order to establish the reasons why such information is being reported.

Findings:

In order to ensure that Reporting Financial Institutions correctly conduct the due diligence and reporting procedures, Peru implemented most of the requirements in accordance with expectations. The key findings were as follows:

• Peru implemented an overarching strategy to ensure compliance with the AEOI Standard and has conducted a risk assessment that took into account a range of relevant information sources, such as the type and size of the RFIs, information from the AML regulator, compliance behaviour for domestic tax purposes regimes, as well as an analysis of the information reported under the AEOI Standard. Peru’s compliance strategy facilitates compliance and incorporates a credible approach to enforcement. Peru intends to keep its compliance strategy and risk assessment under review to ensure its effectiveness on an ongoing basis.

• Peru has taken action to understand its population of Reporting Financial Institutions utilising relevant information sources such as the list of companies with reporting obligations to the SUNAT (e.g. the Financial Information Report, by which all financial accounts opened in Peru are required to be declared and reporting in relation to withholding tax obligations on mutual funds, investment funds and fideicomisos), information from the Financial Intelligence Unit (FIU), from the tax databases and from industry associations, information on the companies regulated by the Superintendency of Banks, Insurance and Private Pension Funds, and the list of Foreign Financial Institutions for FATCA purposes. Peru is taking action to ensure that Reporting Financial Institutions identified are classifying themselves correctly under its domestic rules and ensuring that they report information as required. Peru intends to keep its understanding of its Financial Institution population up to date on a routine basis.

• The SUNAT, the institution responsible for implementing Peru’s compliance strategy, appears to have the necessary powers and resources to discharge its functions. With respect to resourcing, Peru has assigned twelve staff to monitor and ensure compliance by Reporting Financial Institutions, to conduct risk assessment as well as to receive information from RFIs and subsequently exchanging it with exchange partners, which have access to IT systems and tools to carry out their functions. The staff are only allocated full time to AEOI-related tasks on reporting/exchange period. Overall, they appear to have effectively started to implement an operational plan to verify compliance with the requirements, incorporating appropriate compliance activities.

• Peru has started conducting some compliance activities based on a risk-based approach, in particular desk-based reviews, which can include the inspection of records held by Reporting Financial Institutions. So far, the reviews have led to the identification of several Reportable Accounts for which information was not reported or for which information was incorrectly reported. Peru is also planning to expand its in-depth verification activities through carrying out onsite audits in the near future.

• Peru has defined procedures to ensure self-certifications are obtained as required, although has not yet begun to implement them. Peru follows up on undocumented accounts when they are reported.

• Peru has developed and documented procedures to enforce the requirements, including the application of penalties and sanctions for non-compliance when it is identified. It has imposed sanctions on Reporting Financial Institutions that have failed to report on time.

• Peru does not yet have a complete plan to take action to address circumvention of the requirements when such circumvention is detected, although it is taking steps to develop such plan. This reflects its lack of a legal basis to do so, although it is noted that such cases have not yet been identified. Peru is working to implement an anti-avoidance rule applicable to the AEOI Standard.

• It is noted that Peru does not have a jurisdiction-specific list of Non-Reporting Financial Institutions or Excluded Accounts for ongoing monitoring.

Table 3 provides a summary of the specific activities undertaken, or that are planned to be undertaken, in relation to each of the key parts of the framework described above.

Table.9. Activities undertaken

 

Activity type	Activities undertaken
Communication and outreach	Peru has carried out substantial communication and outreach activities, such as meetings held by the SUNAT with the financial sector, the creation of dedicated email addresses to receive queries from Financial Institutions, the publication of guidance and other types of communications on the SUNAT’s webpage and social media accounts to assist Financial Institutions with their obligations under the AEOI Standard.
Verifying that Financial Institutions are reporting as required	Peru has carried out substantial verification activities to ensure that Financial Institutions are reporting as required, such as requiring nil returns, cross-checking relevant information sources, carrying out communicational campaigns and engaging with the Reporting Financial Institutions that had not reported. Peru identified many Financial Institutions incorrectly not reporting and it is following up on these issues with a view to ensuring future compliance.
Verifying whether the information reported is complete and accurate	Peru has started conducting desk-based checks to verify whether the information being reported is complete and accurate, which can include the review of the underlying documentation. It accordingly identified many issues, commonly concerning Reportable Accounts not being reported and accounts reported with issues on TINs and/or DoBs. It is following up on these issues with a view to ensuring future compliance. Although Peru has not yet conducted in-depth audits/onsite visits, it plans to do so in the near future.
Enforcement	Peru has imposed some penalties and sanctions, mainly for Reporting Financial Institutions not reporting information or reporting information with a delay. It is monitoring the impact of these penalties and sanctions with a view to ensuring future compliance. Peru is also reviewing the cases where Reportable Accounts were not reported and where incorrect information was reported to identify suitable enforcement measures.

With respect to the Financial Account information collected and exchanged by Peru, the presence of the key data points of Tax Identification Numbers and the level of undocumented accounts appeared to be in line with most other jurisdictions.

While the collection and reporting of dates of birth is generally higher across jurisdictions, Peru nevertheless reported a much lower rate of collection of dates of birth when compared to other jurisdictions. This is a key data point for exchange partners to effectively utilise the information. Follow-up discussions confirmed that Peru is aware of these issues and is taking steps to address them.

Feedback from Peru’s exchange partners indicated that, compared to what they generally experience when seeking to match information received from their exchange partners with their taxpayer database, they achieved a relatively lower level of success when seeking to match information received from Peru. Furthermore, one exchange partner highlighted an issue with respect to the information received related to an abnormal variance in the balance of an account, which was communicated informally to Peru. Follow-up discussions confirmed that Peru is aware of these issues and is seeking to improve the situation.

Based on these findings it was concluded that, overall, Peru is meeting expectations in ensuring that Reporting Financial Institutions correctly conduct the due diligence and reporting procedures, including by having in place the required administrative compliance framework and related procedures. It was also noted that there is room for improvement with respect to the full implementation of the compliance strategy, including in-depth reviews and the review of self-certifications. Peru is therefore encouraged to continue its implementation process accordingly, including by addressing the recommendations made.

Recommendations:

Peru should continue to implement and expand its activities to verify that Reporting Financial Institutions are correctly conducting their due diligence and reporting obligations, specifically including in-depth reviews.

Peru should put in place a clearly defined policy to ensure that, where circumvention of the AEOI Standard is identified, action is taken to address it. Reference is made to the recommendation made when assessing Peru’s legal frameworks implementing the AEOI Standard.

Peru should implement its plans to monitor and verify whether Reporting Financial Institutions are obtaining valid self-certifications as required.

SR 1.6 Jurisdictions should collaborate on compliance and enforcement. This requires jurisdictions to:

a) use all appropriate measures available under the jurisdiction’s domestic law to address errors or non-compliance notified to the jurisdiction by an exchange partner; and

b) have in place effective procedures to notify an exchange partner of errors that may have led to incomplete or incorrect information reporting or non-compliance with the due diligence or reporting procedures by a Reporting Financial Institution in the jurisdiction of the exchange partner.

Findings:

In order to collaborate on compliance and enforcement, it appears that Peru implemented all of the requirements in relation to issues notified to them (i.e. under Section 4 of the MCAA or equivalent) in accordance with expectations. While no such notifications have yet been received, Peru has the necessary systems and procedures to process them as required. It also appears that Peru will notify its partners effectively of errors or suspected non-compliance it identified when utilising the information received.

Based on these findings it was concluded that Peru is fully meeting expectations in relation to collaborating with its exchange partners to ensure that Reporting Financial Institutions correctly conduct the due diligence and reporting procedures. Peru is encouraged to continue its implementation process accordingly, to ensure its ongoing effectiveness.

Recommendations:

No recommendations made.

CR2 Effectiveness in practice: Jurisdictions should exchange the information effectively in practice, in a timely manner, including by sorting, preparing, validating and transmitting it in accordance with the AEOI Standard

Rating: On Track

Peru’s implementation of the AEOI Standard is on track with respect to exchanging the information effectively in practice, including in relation to correctly transmitting the information in a timely manner (SRs 2.5 – 2.8) and providing corrections, amendments or additions to the information (SR 2.9). However, some issues were found with respect to sorting, preparing and validating the information (SR 2.4). Peru is encouraged to continue its implementation process accordingly, to ensure its ongoing effectiveness.

SR 2.4 Jurisdictions should sort, prepare and validate the information in accordance with the CRS XML Schema and the associated requirements in the CRS XML Schema User Guide and the File Error and Correction-related validations in the Status Message User Guide (i.e. the 50000 and 80000 range).

Findings:

13 exchange partners highlighted particular issues with respect to preparation and format of the information sent by Peru (representing 17% of its partners). These generally related to particular file errors, e.g. errors when identifying resent files. More generally, 11 (or 14.5%) of Peru’s exchange partners reported rejecting 25% or more of the files received, of which 3 (or 4%) reported rejecting more than 50% of files received, due to the technical requirements not being met. This is a relatively very high amount when compared to other jurisdictions and it has not improved over time. It was noted that Peru has already successfully addressed all of the issues.

Figure.2.Technical issues raised by Peru’s exchange partners

Based on these findings it was concluded that, overall, Peru is meeting expectations in relation to sorting, preparing and validating the information. It was also noted that there is room for improvement with respect to validation and preparation of files before they are sent. Peru is therefore encouraged to continue its implementation process accordingly, including in relation to the areas highlighted.

Recommendations:

Peru should review its systems and procedures for sorting, preparing and validating the information to send to its exchange partners, to ensure they meet the requirements of the AEOI Standard.

SR 2.5 Jurisdictions should agree and use, with each exchange partner, transmission methods that meet appropriate minimum standards to ensure the confidentiality and integrity of the data throughout the transmission, including its encryption to a minimum secure standard.

Findings:

In order to put in place an agreed transmission method that meets appropriate minimum standards in confidentiality, integrity of the data and encryption for use with each of its exchange partners, Peru linked to the CTS.

Based on these findings it was concluded that Peru is fully meeting expectations in relation to agreeing and using appropriate transmission methods with each of its partners. Peru is encouraged to continue to ensure the ongoing effectiveness of its implementation.

Recommendations:

No recommendations made.

SR 2.6 Jurisdictions should carry out all exchanges annually within nine months of the end of the calendar year to which the information relates.

Findings:

Feedback from Peru’s exchange partners did not raise any concerns with respect to timeliness of the exchanges by Peru and therefore with respect to Peru’s implementation of this requirement.

Based on these findings it was concluded that Peru is fully meeting expectations in relation to exchanging the information in a timely manner. Peru is encouraged to continue to ensure the ongoing effectiveness of its implementation.

Recommendations:

No recommendations made.

SR 2.7 Jurisdictions should send the information in accordance with the agreed transmission methods and encryption standards.

Findings:

Feedback from Peru’s exchange partners did not raise any concerns with respect to Peru’s use of the agreed transmission methods and therefore with Peru’s implementation of this requirement.

Based on these findings it was concluded that Peru is fully meeting expectations in relation to sending the information in accordance with the agreed transmission methods and encryption standards. Peru is encouraged to continue to ensure the ongoing effectiveness of its implementation.

Recommendations:

No recommendations made.

SR 2.8 Jurisdictions should have the systems in place to receive information and, once it has been received, should send a status message to the sending jurisdictions in accordance with the CRS Status Message XML Schema and the related User Guide.

Findings:

12 exchange partners highlighted delays in the sending of status messages by Peru, representing 12.5% of its partners. This represents a very high proportion of partners and has not improved over time. It was noted that Peru successfully addressed all of the issues and sent the status messages to its exchange partners.

Based on these findings it was concluded that, overall, Peru is meeting expectations in relation to the receipt of the information. It was also noted that there is room for improvement with respect to sending status messages to partner jurisdictions in a timely manner. Peru is encouraged to continue to ensure the ongoing effectiveness of its implementation, including in relation to the area highlighted.

Recommendations:

Peru should ensure it sends status messages to all of its exchange partners in a timely manner.

SR 2.9 Jurisdictions should respond to a notification from an exchange partner as referred to in Section 4 of the Model CAA (which may include Status Messages) in accordance with the timelines set out in the Commentary to Section 4 of the Model CAA. In all other cases, jurisdictions should send corrected, amended or additional information received from a Reporting Financial Institution as soon as possible after it has been received.

Findings:

Peru appears ready to respond to notifications and to provided corrected, amended or additional information in a timely manner and no such concerns were raised by Peru’s exchange partners and therefore with respect to Peru’s implementation of these requirements.

Based on these findings it was concluded that Peru appears to be meeting expectations in relation to responding to notifications from exchange partners and the sending of corrected, amended or additional information. Peru is encouraged to continue to ensure the ongoing effectiveness of its implementation.

Recommendations:

No recommendations made.

Comments by the assessed jurisdiction

No comments made.