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 Duration 14 hours

Course Outline

Introduction to CRS and Global Tax Transparency

  • The history and objectives of the CRS and the Automatic Exchange of Information (AEOI)
  • Identifying Reporting Financial Institutions and defining the scope of reportable accounts
  • Examining the relationship between CRS and FATCA, including overlapping and distinct requirements

Legal & Regulatory Framework

  • Jurisdictional implementation models and legal instruments, such as the Multilateral Competent Authority Agreement (MCAA) and domestic legislation
  • Recent consolidated texts and amendments affecting due diligence and scope
  • Compliance obligations, specific timelines, and penalties for non-compliance

Due Diligence Fundamentals: Identifying Tax Residency

  • Necessary documentation, including self-certifications and reliable documentary evidence
  • Indicia search procedures applicable to both new and pre-existing accounts
  • Adopting a broader due diligence approach, leveraging AML/KYC information to establish 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, with specific considerations for service providers

FATCA-like Requirements and Comparative Best Practices

  • Key similarities with FATCA, covering classification, reporting mechanics, and the treatment of entities and beneficiaries
  • Differences to account for, including scope, bilateral versus multilateral implementation, and jurisdictional variations
  • Practical mapping exercises to convert FATCA controls into CRS-compliant processes

Reporting, Exchange Mechanisms, and Audit Readiness

  • CRS report formats and transmission channels, including specific 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

  • Designing governance frameworks, policies, and segregation of duties to ensure CRS compliance
  • Training, quality assurance, and exception handling for complex and 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: Configure 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

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

Audience

  • Compliance officers and legal teams
  • Onboarding, KYC, and client due diligence staff
  • Tax reporting and operations teams within financial institutions

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