Course Outline

Introduction to CRS and Global Tax Transparency

  • History and purpose of the CRS and Automatic Exchange of Information (AEOI)
  • Who must report: Reporting Financial Institutions and scope of reportable accounts
  • How CRS relates to FATCA and where their requirements overlap and differ

Legal & Regulatory Framework

  • Jurisdictional implementation models and legal instruments (MCAA, domestic legislation)
  • Recent consolidated texts and amendments impacting due diligence and scope
  • Compliance obligations, timelines, and penalties for non-compliance

Due Diligence Fundamentals: Identifying Tax Residency

  • Required documentation: self-certifications and reliable documentary evidence
  • Indicia search procedures for new and pre-existing accounts
  • Wider approach to due diligence and use of AML/KYC information to determine tax residence

Operationalizing CRS: Onboarding, Data Capture, and Systems

  • Integrating CRS checks into client onboarding and periodic review workflows
  • Data elements required for reporting and practical approaches to data quality and retention
  • Using automation and vendor tools versus manual processes; considerations for service providers

FATCA-like Requirements and Comparative Best Practices

  • Key commonalities with FATCA (classification, reporting mechanics, treatment of entities and beneficiaries)
  • Differences to plan for (scope, bilateral vs. multilateral implementation, jurisdictional variance)
  • Practical mapping exercises: converting FATCA controls into CRS-compliant processes

Reporting, Exchange Mechanisms, and Audit Readiness

  • Formats and transmission channels for CRS reports; jurisdictional submission requirements
  • Preparing for audits and regulator reviews: 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 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 a set of sample account files and self-certifications; determine reportability
  • Lab: Configure a simple data-extraction and reporting checklist; produce a mock CRS XML extract
  • Case study: Handling complex entity structures, trusts, and controlling persons under CRS rules

Summary and Next Steps

Requirements

  • An understanding of financial services or compliance functions
  • Familiarity with basic tax concepts and customer onboarding
  • Experience with AML/KYC processes is helpful but not required

Audience

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

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