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 Duration 14 hours

Course Outline

Introduction to CRS and Global Tax Transparency

  • The origins and objectives of the CRS and the Automatic Exchange of Information (AEOI).
  • Defining Reporting Financial Institutions and the scope of reportable accounts.
  • Understanding the relationship between CRS and FATCA, highlighting overlaps and distinct requirements.

Legal & Regulatory Framework

  • Jurisdictional implementation models and associated legal instruments, including Multilateral Competent Authority Agreements (MCAA) and domestic laws.
  • Recent consolidated texts and amendments that affect due diligence and scope.
  • Compliance duties, statutory timelines, and penalties associated with non-compliance.

Due Diligence Fundamentals: Identifying Tax Residency

  • Essential documentation requirements, including self-certifications and reliable documentary proof.
  • Procedures for conducting indicia searches on new and pre-existing accounts.
  • Utilizing a broader due diligence approach and leveraging AML/KYC data to ascertain tax residency.

Operationalizing CRS: Onboarding, Data Capture, and Systems

  • Embedding CRS verification into client onboarding and periodic review workflows.
  • Key data elements for reporting and strategies for ensuring data quality and retention.
  • Evaluating automation and vendor tools against manual processes, with specific considerations for service providers.

FATCA-like Requirements and Comparative Best Practices

  • Shared elements with FATCA, such as classification, reporting mechanics, and the treatment of entities and beneficiaries.
  • Key differences to consider, including scope, bilateral versus multilateral implementation, and jurisdictional variations.
  • Practical mapping exercises to adapt FATCA controls into CRS-compliant processes.

Reporting, Exchange Mechanisms, and Audit Readiness

  • Standard formats and transmission channels for CRS reporting, along with jurisdiction-specific submission rules.
  • Preparing for audits and regulatory reviews through robust documentation, traceability, and evidence of due diligence.
  • Examples of reporting workflows and reconciliation checks.

Risk Management, Governance, and Internal Controls

  • Establishing governance frameworks, policies, and segregation of duties to support CRS compliance.
  • Implementing training, quality assurance, and exception handling for complex or entity-based accounts.
  • Remediation strategies and multi-jurisdiction coordination for legacy accounts.

Practical Labs and Case Studies

  • Lab: Evaluate and verify sample account files and self-certifications to determine reportability.
  • Lab: Set up a basic data-extraction and reporting checklist and generate a mock CRS XML extract.
  • Case study: Managing complex entity structures, trusts, and controlling persons under CRS regulations.

Summary and Next Steps

Requirements

  • A solid grasp of financial services or compliance operations.
  • A familiarity with foundational tax principles and customer onboarding procedures.
  • Experience with AML/KYC processes is advantageous but not mandatory.

Target Audience

  • Compliance officers and legal department members.
  • Staff responsible for onboarding, KYC, and client due diligence.
  • Tax reporting and operations teams within financial institutions.

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