Bringing overseas holdings into compliance and keeping them there
A family group held companies overseas that had been set up over many years. We found what had not been reported and put it right.
A family group had set up several overseas companies over many years, some by the family, some by group companies. Nobody held a complete list, and reporting to the bank and regulator had been handled by different people at different times.
The group was now planning a financing that required a clean compliance record, and wanted to know where it stood before anyone asked.
What we did
- Step 1
Build the register of overseas holdings
We listed every overseas entity, who held it, how it was funded, and what had been reported for it at each stage.
- Step 2
Compare against the rules at the time
We checked each investment and each later transfer against the rules in force when it happened, and noted what was reported, late or missing.
- Step 3
Regularise through the authorised route
We prepared the late reporting and the applications to regularise past gaps through the authorised bank and, where required, the regulator, with fees and compounding where they applied.
- Step 4
Install a yearly routine
We set up a calendar for the annual returns and performance reports each overseas holding requires, with an owner and a check before the due date.
A complete register, a clean record and a routine that holds.
The group went into the financing with a single register of overseas holdings and a record of what had been regularised.
Annual reporting for each overseas entity was on a calendar with a named owner, so the position stayed clean.
One register
Every overseas holding was listed with its funding and reporting history.
Past gaps regularised
Late and missing reporting was put right through the proper route.
A yearly routine
Annual returns for each holding had an owner and a due date.
Foreign exchange rules are forgiving about late reporting that is put right voluntarily. They are not about gaps that are found.
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