14 Comments on "Storing Gambling Proceeds Offshore"

  1. Hi again Streber, sorry, I couldn’t find any contact e-mails and I didn’t know where to ask this. I just wanted to check with you since you are the expert, does CRS/AEOI officially have a deadline for reporting financial institutions to notify their clients their accounts will be automatically reported by 31st of January the year following to the reporting year? Or has this changed? Please if possible check, this would really mean a lot. Thanks.

    • I couldn’t find any contact e-mails

      That’s intentional.

      does CRS/AEOI officially have a deadline for reporting financial institutions to notify their clients their accounts will be automatically reported by 31st of January the year following to the reporting year? Or has this changed? Please if possible check, this would really mean a lot. Thanks.

      I’m sorry, but I cannot answer this since you are effectively asking for an interpretation of legal texts, i.e. legal advice. For one, the client notification regulations are implemented on a per-country basis (each country passes its own laws). While these are usually modelled very closely after OECD recommendation, it would be prudent to understand the specifics of the involved jurisdiction/s, which state that “The notification must be made by 31 January in the calendar year following the first year in which the account held by the individual is a reportable account maintained by the Reporting Financial Institution.”

  2. Hi Streber, sorry to bring up an old topic, but I couldn’t find a new one. First of all, thanks for all your insight, your site is fantastic, the depth of quality information unmatched. I just have one question if possible. Do you perhaps know what the status is of Skrill and other e-wallets concerning AEOI and CRS at the moment for the year of 2016? There is very contradicting information out there, Skrill and Neteller are giving out vague responses “they can neither confirm nor deny they will have to be involved in the programme”, and we know that the e-money providers have been put on the CRS reporting entities list in late 2016, so perhaps their involvement (reporting) won’t come for 2016 but from a later year? This is what I wanted to ask you about, what are your thoughts on this? As far as I know all banks and reporting FI have already sent the KYC/self certification documentation but e-wallets haven’t sent anything, nor have they updated their terms of use, which they are obliged by law if they should become a reporting entity. Now I’m perfectly aware they will become a reporting FI sooner or later, I was just wondering what your thoughts are for 2016, will they participate or not? Also, if they are based on the Isle of Man, but there is no multilateral agreement with the Isle of Man AND the reporting jurisdiction, what happens then? Because I see the Isle of Man only has 41 bilateral connections. Best regards, Ramon.

    • For the immediate future, it seems e-wallets are left out of scope and not actively targeted. For one, people rarely store significant sums of money there. Funds are instead settled into bank accounts, where reporting would kick in.

      If I recall correctly, the Paysafe Group (Skrill, Neteller) has said that they will not conduct reporting until CRS until told to do so.

      The CRS defines Non-Reporting Financial Institutions to include institutions that pose a low risk. Given the low balances and low transactions (when compared to banks) that e-wallets usually handle, they can probably get away with this for a while until CRS is so commonplace in banking that e-wallets will be expected to start reporting.

      Time will tell what will actually happen. For now, non-compliance or compliant non-reporting by e-wallets appears tolerated but that’s unlikely to remain the case for very long.

      • Hi Streber, thank you very much for the information. What puzzled me at first was the fact that under the amended directive they were included, but hopefully too late for 2016 to be under the scope off the bat. Also, additionally, I got a reply from Skrill today that I believe could be considered a legal contract, that they are currently out of it, confirming what you said.

        1) this was my reason for concern initially:

        The initial guidance concerning e-wallets has been superseded by the guidance made on May 16 2016, and it looks like e-wallets were added as Financial institutions in that guideline. See following link, specifically part IEIM400750: https://haydonperryman.com/gb/guidance/dac/

        What I was hoping and still am, that 2016 cannot be under the scope due to the fact they were only added that late.

        2) And this is the response from skrill to me earlier today:
        Dear xxxx,
        Thank you for your recent enquiry into the OECD /Standard for automatic exchange of financial account for tax matters.

        Paysafe is compliant with all reporting obligations related to financial accounts. Currently, the OECD’s Standard for Automatic Exchange of Financial Account Information (or Common Reporting Standards) do not apply to e-money issuers. Paysafe continues to follow this legislation as it develops.

        Kind regards,
        Skrill Help Team

      • One more thing Streber, and I won’t bother you any more (thank you for your time and effort btw).
        Is it official that unless a reporting FI announces to the reportable person that he/she would be reported for the previous year, until 31st JAN, that they can no longer report for that year (previous)? Thanks.

        • First, just my usual caveat… What you’re asking is basically legal advice, and I unfortunately cannot give such advice under my Streber persona. Because there can be minute differences in the treaties that are relevant to you depending on which jurisdictions you live in, work in, are a citizen of, your ewallet is licensed in, et cetera, there is no way to accurate answer your question without digging into considerable detail.

          Generally, exchange of information treaties are not retroactive. You can reasonably expect but not necessarily expect to be fully guaranteed notice prior to reporting commencing, because the situation with e-wallets is a bit unusual in that under some interpretations they should already be reporting. Once they do start reporting, it’s not something brand-new, as is the case with CRS and regular banks right now.

          • You are absolutely right, and I apologize if I crossed any lines and am bothering you at this point. Any advice or feedback from you is of course not taken as a legal advice and there is no liability, we are just exchanging information, well, you are sharing your valuable insight with me, and I truly appreciate it. I have shared your website with at least a dozen investor colleagues and friends, and this is the bare minimum I can do.

            About the CRS, why I was and still am, so puzzled. Because all we see are amendments, directives, CRS handbook rules, but there is nothing set in stone, nothing is guaranteed. The early adopters (both countries Skrill is based in, and the country of my residence) will exchange information in SEP 2017 for the year of 2016. Balances and all income, dividends, etc for the year of 2016.

            e-money was initially excluded but from an amended directive from HMRC in SEP 2016, they are included. However, and I can not find this information for sure anywhere – no one knows when this will be applied to them.

            CRS handbooks do clearly state however, and I hope at least something can be legally binding in all this sea of information, that the reporting financial institution has to inform the reportable person until JAN 31st the year following to the reporting year. Meaning, if any bank, insurance company, brokerage firm or an e-money institution for that matter, plans to report anything for 2016, they have to announce it to the reportable persons until 31st JAN 2017, asking for KYC/Residential status.

            Seemingly e-money will join the reporting at a later date, and hopefully from 2017 onwards, not backwards.

            The only problem with this OECD initiative is, most information is untrustworthy, you have amended directives over old directives, updates and dates, but nothing is known for sure, which is what frustrates people. I’m sure that people with substantial investments have already moved their assets to non-AEOI jurisdictions, but with us mid level arbers, traders and freelancers, we are basically left to the gamble of OECD’s directives and implementations.

            But at least Skrill said they are not currently participating, which means 2016 will not be reported. By law they would have only 25 more days to inform every customer, something reporting FIs (mostly banks as this is where the emphasis is on) have done a year ago, and throughout the last year. It’s not something you can do in the last week. Anyway, thanks again for your feedback, I will continue to read your content on a daily basis and will recommend you to everyone I’m in the business with.

  3. Hi streber,

    Great article. But I think that the E-wallets will be required to report balances as they are classified as custodians under the OECD common reporting standard.

    Can you please confirm the same ? Have tried searching and even asking them.. but do not get a reply from them for the same.

    • Thanks for your feedback!

      E-wallets are financial institutions and are technically covered in OECD EOI (Exchange Of Information) agreements. However, because there are limits on how much money an e-wallet can process and because they are not subject to banking secrecy laws, they have hitherto not been given much attention when it comes to EOI.

      E-wallets do receive requests for information under EOI agreements and release information.

      • So from 2017 skrill/neteller will automatically send the information based on the MCAA common reporting standard. Just now they just share the information as and when requsted by the taxing country but after the AEOI kicks in from 2017 the information will flow directly to the tax country right ?

        • Theoretically – yes.

          In reality, the focus is on getting banks and bank-like institutions to start AEOI. E-wallets are not a high priority at the moment. However, there are relatively few e-wallets out there (compared to number of banks). Especially since Neteller (Optimal Payments) now owns Skrill, you only need them, PayPal, and maybe one or two more to cover well over 80% of the market. Although I doubt that e-wallets will be included in AEOI by 2017, once OECD and others decide to push for it, it won’t take long for the e-wallets to fall in line.

          E-wallets, far more so than banks, are tech companies. While banks have needed years to prepare for AEOI, e-wallet companies are usually run in a more technologically savvy way and can likely implement AEOI much faster.

  4. Hi Streber,

    Your website is amazing and a list of banks is so a great tool, that I am constantly using that along with OECD list of signatories of the Multilateral Competent Authority Agreement, in order to help my clients to maintain some secrecy and be free for a while from reporting.

    I am working in similar field to you, but I am not so long in a business and don’t have so much experience as you, so I find your website a unique tool to learn and research more, while servicing more complicated matters.

    I would like to ask you a question as I need help:

    I have a client: Panama company, nominee directors, mobile bearer shares, PoA for UBO (EU citizen) and company is in the business advertising and internet marketing, using affiliate programs, but doing marketing for gambling and we have trouble to open bank account outside EU, preferably from jurisdiction not already listed in OECD Automatic Tax exchange. Even though client is not directly liked to gambling and only does online advertisement.
    Can you recommended some jurisdiction or even some bank? Client can store bigger deposit, but only after few months of gathering money from a revenue.

    Just a few names will be a game changer for me.

    Thank you very much in advance.

    Best Regards,


    • Hi Invest,

      Thanks for your kind words.

      Unfortunately, because of the (probably unnecessarily) complex structure with the bearer shares and nominees, banking is going to be very difficult unless you yourself are a QI (qualified introducer). Chances are you will need to hire an intermediary.

      If it weren’t for the gambling aspect, the Middle East (Bahrain, Lebanon) would be an option but those banks don’t even like affiliates generally. Unless we’re talking 1 million USD and up deposit.

      Have you looked at Vanuatu or Guatemala? What about Panama itself?

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