here is the official reply from the issuing bank:

So far our position is going in line with the following statement: Gibraltar is classed as an "Early Adopter" of the OECD's CRS (Common Reporting Standard). As such, unless otherwise defined, WaveCrest would be subject to the same reporting obligations as any other financial institution located in any jurisdiction which has adopted the CRS. However, the classes of reporting institutions have not yet been fully defined and there is a possibility that e-money firms (such as WaveCrest) may be exempted. Until such time as a final decision is taken by the authorities we will not be able to confirm fully.

So you can rely on it whenever you have such questions, until we ourselves will get more clarity regarding CRS influence on e-money.