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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).
  • Identifying who must report: Reporting Financial Institutions and the scope of reportable accounts.
  • Understanding the relationship between CRS and FATCA, including overlapping and distinct requirements.

Legal & Regulatory Framework

  • Jurisdictional implementation models and legal instruments, such as MCCAs and domestic legislation.
  • Recent consolidated texts and amendments affecting due diligence and scope.
  • Compliance obligations, timelines, and penalties for non-compliance.

Due Diligence Fundamentals: Identifying Tax Residency

  • Essential documentation: self-certifications and reliable documentary evidence.
  • Indicia search procedures for both new and pre-existing accounts.
  • A broader approach to due diligence, utilizing AML/KYC information to establish tax residence.

Operationalizing CRS: Onboarding, Data Capture, and Systems

  • Integrating CRS checks into client onboarding and periodic review workflows.
  • Reporting data elements and practical strategies for data quality and retention.
  • Comparing automation and vendor tools versus manual processes, including 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.
  • Differences to consider, such as scope, bilateral versus multilateral implementation, and jurisdictional variance.
  • Practical mapping exercises: translating FATCA controls into CRS-compliant processes.

Reporting, Exchange Mechanisms, and Audit Readiness

  • Formats and transmission channels for CRS reports, along with jurisdictional submission requirements.
  • Preparing for audits and regulator reviews through documentation, traceability, and evidence of due diligence.
  • Sample reporting workflows and reconciliation checks.

Risk Management, Governance, and Internal Controls

  • Developing 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: Review and validate sample account files and self-certifications to determine reportability.
  • Lab: Set up a basic 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

  • Working knowledge of financial services or compliance functions.
  • Familiarity with fundamental tax concepts and customer onboarding.
  • Experience with AML/KYC processes is advantageous but not mandatory.

Target Audience

  • Compliance officers and legal teams.
  • Staff involved in onboarding, KYC, and client due diligence.
  • Tax reporting and operations teams within financial institutions.

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