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 Duration 14 hours

Course Outline

Introduction to CRS and Global Tax Transparency

  • The history and objectives of CRS and the Automatic Exchange of Information (AEOI)
  • Identifying Reporting Financial Institutions and the scope of reportable accounts
  • The relationship between CRS and FATCA, including overlaps and differences in requirements

Legal and Regulatory Framework

  • Jurisdictional implementation models and relevant legal instruments, such as the MCAA and domestic legislation
  • Impact of recent consolidated texts and amendments on due diligence and scope
  • Compliance obligations, deadlines, and consequences of non-compliance

Due Diligence Fundamentals: Identifying Tax Residency

  • Essential documentation, including self-certifications and reliable documentary evidence
  • Indicia search procedures applicable to both new and pre-existing accounts
  • Broadening the due diligence approach by leveraging AML and KYC data to determine tax residency

Operationalizing CRS: Onboarding, Data Capture, and Systems

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

FATCA-like Requirements and Comparative Best Practices

  • Commonalities with FATCA, including classification, reporting mechanics, and the treatment of entities and beneficiaries
  • Differences requiring strategic planning, such as scope, bilateral versus multilateral implementation, and jurisdictional variances
  • Practical mapping exercises to translate FATCA controls into CRS-compliant processes

Reporting, Exchange Mechanisms, and Audit Readiness

  • Reporting formats, transmission channels, and jurisdictional submission requirements
  • Preparing for audits and regulatory reviews through proper 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 for CRS compliance
  • Training, quality assurance, and handling exceptions for complex or entity accounts
  • Remediation strategies and coordinating across jurisdictions for legacy accounts

Practical Labs and Case Studies

  • Lab: Reviewing and validating sample account files and self-certifications to determine reportability
  • Lab: Configuring 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

  • Basic understanding of financial services or compliance functions
  • Familiarity with fundamental tax concepts and client onboarding
  • Experience with AML and KYC processes is beneficial 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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