Hi Steven,
"It's under the Common Reporting Standard that came into effect on 1 January 2016"
Below is from the FAQ section of the Revenue on this.
8. Residence address test for Lower Value Accounts. A jurisdiction may allow Financial Institutions to determine an Account Holder’s residence based on the residence address provided by the account holder so long as the address is current and based on Documentary Evidence. The residence address test may apply to Preexisting Lower Value Accounts (less than $1 million) held by Individual Account Holders. This test is an alternative to the electronic indicia search for establishing residence and if the residence address test cannot be applied, because, for example, the only address on file is an “in-care-of” address, the Financial Institution must perform the electronic indicia search. The residence address test option is not available for FATCA. The EU Directive includes the residence address test. (Section III, subparagraph B(1); Commentary on Section III, subparagraph 7-13) 9. Optional Exclusion from Due Diligence for Preexisting Entity Accounts of less than
As the policy in question is for Life Cover only whereas the above appears to deal with Investment Accounts so surely should not be applied here?
Thanks
Bedlam