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 Duration 14 hours

Course Outline

Introduction to CRS and Global Tax Transparency

  • The history and objectives of the CRS and Automatic Exchange of Information (AEOI).
  • Identifying Reporting Financial Institutions and defining the scope of reportable accounts.
  • Analyzing the relationship between CRS and FATCA, highlighting areas of overlap and divergence.

Legal & Regulatory Framework

  • Exploring jurisdictional implementation models and legal instruments, including the MCAA and domestic legislation.
  • Reviewing recent consolidated texts and amendments that affect due diligence and scope.
  • Understanding compliance obligations, deadlines, and the penalties associated with non-compliance.

Due Diligence Fundamentals: Identifying Tax Residency

  • Examining required documentation, such as self-certifications and reliable documentary evidence.
  • Implementing indicia search procedures for both new and pre-existing accounts.
  • Adopting a broader due diligence approach, utilizing AML/KYC data to determine tax residence.

Operationalizing CRS: Onboarding, Data Capture, and Systems

  • Embedding CRS checks into client onboarding and periodic review workflows.
  • Identifying required data elements for reporting and strategies for maintaining data quality and retention.
  • Evaluating the use of automation and vendor tools versus manual processes, with specific considerations for service providers.

FATCA-like Requirements and Comparative Best Practices

  • Identifying commonalities with FATCA, including classification, reporting mechanics, and the treatment of entities and beneficiaries.
  • Anticipating differences in scope, implementation models (bilateral vs. multilateral), and jurisdictional variations.
  • Engaging in practical mapping exercises to translate FATCA controls into CRS-compliant processes.

Reporting, Exchange Mechanisms, and Audit Readiness

  • Reviewing CRS report formats, transmission channels, and jurisdictional submission requirements.
  • Preparing for audits and regulatory reviews through effective documentation, traceability, and evidence of due diligence.
  • Examining sample reporting workflows and reconciliation checks.

Risk Management, Governance, and Internal Controls

  • Structuring governance frameworks, policies, and segregation of duties to support CRS compliance.
  • Establishing training, quality assurance, and exception handling protocols for complex and entity accounts.
  • Developing remediation pathways and coordinating multi-jurisdiction efforts for legacy accounts.

Practical Labs and Case Studies

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

Summary and Next Steps

Requirements

  • A solid understanding of financial services or compliance functions.
  • Familiarity with fundamental tax concepts and customer onboarding procedures.
  • 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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