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 Duration 14 hours

Course Outline

Introduction to CRS and the Landscape of Global Tax Transparency

  • The origins and objectives of the CRS and the Automatic Exchange of Information (AEOI)
  • Identifying Reporting Financial Institutions and defining the scope of reportable accounts
  • Analyzing the relationship between CRS and FATCA, highlighting overlaps and distinct differences

Legal and Regulatory Context

  • Exploring jurisdictional implementation models and key legal instruments such as the MCAA and domestic legislation
  • Reviewing recent consolidated texts and amendments that affect due diligence scope
  • Understanding compliance duties, critical timelines, and the penalties associated with non-compliance

Due Diligence Basics: Determining Tax Residency

  • Required documentation, including self-certifications and reliable documentary proof
  • Indicia search methodologies for both new and pre-existing accounts
  • Applying a broader due diligence approach by leveraging AML/KYC data to ascertain tax residence

Implementing CRS: Onboarding, Data Management, and System Integration

  • Embedding CRS checks within client onboarding and periodic review workflows
  • Identifying essential data elements for reporting and adopting best practices for data quality and retention
  • Evaluating the use of automation and vendor tools against manual processes, with specific considerations for service providers

FATCA-Analogous Requirements and Comparative Best Practices

  • Identifying key similarities with FATCA, including classification, reporting mechanics, and entity handling
  • Recognizing differences in scope, implementation models (bilateral vs. multilateral), and jurisdictional variations
  • Conducting practical mapping exercises to adapt FATCA controls into CRS-compliant processes

Reporting, Exchange Protocols, and Audit Preparedness

  • Understanding the formats and transmission channels for CRS reports, along with jurisdictional submission specifics
  • Preparing for audits and regulator reviews through rigorous documentation, traceability, and evidence of due diligence
  • Examining sample reporting workflows and reconciliation verification steps

Risk Management, Governance, and Internal Control Structures

  • Establishing governance frameworks, policies, and segregation of duties to ensure CRS adherence
  • Implementing training, quality assurance, and exception handling for complex or entity-based accounts
  • Developing remediation strategies and multi-jurisdiction coordination for legacy account issues

Practical Labs and Real-World Case Studies

  • Exercise: Reviewing and validating sample account files and self-certifications to determine reportability
  • Exercise: Configuring a basic data-extraction and reporting checklist to generate a mock CRS XML output
  • Case study: Navigating complex entity structures, trusts, and controlling persons under CRS regulations

Conclusion and Future Directions

Requirements

  • A solid grasp of financial services or compliance functions
  • Knowledge of fundamental tax principles and customer onboarding processes
  • Experience with AML/KYC procedures is advantageous but not mandatory

Target Audience

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

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