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 Duration 14 hours (2 days)

Course Outline

Introduction to CRS and Global Tax Transparency

  • The history and objectives of the CRS and Automatic Exchange of Information (AEOI)
  • Identification of Reporting Financial Institutions and the scope of reportable accounts
  • The relationship between CRS and FATCA, highlighting overlaps and distinctions

Legal and Regulatory Framework

  • Jurisdictional implementation models and legal instruments, including MCAs and domestic legislation
  • Recent consolidated texts and amendments affecting due diligence and scope
  • Compliance obligations, reporting timelines, and penalties for non-adherence

Due Diligence Fundamentals: Identifying Tax Residency

  • Essential documentation: self-certifications and reliable documentary evidence
  • Indicia search procedures applicable to new and pre-existing accounts
  • A broader due diligence approach leveraging AML/KYC information to determine tax residence

Operationalizing CRS: Onboarding, Data Capture, and Systems

  • Integrating CRS checks into client onboarding and periodic review workflows
  • Required data elements for reporting, along with practical strategies for data quality and retention
  • Evaluating automation and vendor tools against manual processes; considerations for service providers

FATCA-like Requirements and Comparative Best Practices

  • Key similarities with FATCA regarding classification, reporting mechanics, and the treatment of entities and beneficiaries
  • Distinctions to consider, such as scope, bilateral versus multilateral implementation, and jurisdictional variations
  • Practical mapping exercises to translate FATCA controls into CRS-compliant processes

Reporting, Exchange Mechanisms, and Audit Readiness

  • CRS report formats, transmission channels, and jurisdictional submission requirements
  • Preparing for audits and regulator reviews through documentation, traceability, and due diligence evidence
  • Sample reporting workflows and reconciliation checks

Risk Management, Governance, and Internal Controls

  • Establishing governance frameworks, policies, and segregation of duties for CRS compliance
  • Training, quality assurance, and exception handling for complex entity accounts
  • Remediation pathways and multi-jurisdiction coordination for legacy accounts

Practical Labs and Case Studies

  • Lab: Reviewing and validating sample account files and self-certifications to determine reportability
  • Lab: Configuring a simple data-extraction and reporting checklist to generate a mock CRS XML extract
  • Case study: Managing complex entity structures, trusts, and controlling persons under CRS rules

Summary and Next Steps

Requirements

  • A foundational understanding of financial services or compliance functions
  • Familiarity with basic tax concepts and customer onboarding processes
  • Experience with AML/KYC processes is advantageous but not mandatory

Target Audience

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

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