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 Duration 14 hours

Course Outline

Introduction to CRS and Global Tax Transparency

  • The origins and objectives of the CRS and Automatic Exchange of Information (AEOI)
  • Entities required to report: Reporting Financial Institutions and the scope of reportable accounts
  • The relationship between CRS and FATCA, including overlapping and distinct requirements

Legal & Regulatory Landscape

  • Jurisdictional implementation models and legal instruments (MCAA, national legislation)
  • Recent consolidated texts and amendments affecting due diligence and scope
  • Compliance duties, deadlines, and penalties for non-adherence

Due Diligence Basics: Determining Tax Residency

  • Necessary documentation: self-certifications and reliable documentary proof
  • Indicia search procedures for both new and pre-existing accounts
  • A broader due diligence approach leveraging AML/KYC data to ascertain tax residency

Operationalizing CRS: Onboarding, Data Collection, and Systems

  • Embedding CRS checks into client onboarding and periodic review workflows
  • Data elements necessary for reporting, along with strategies for data quality and retention
  • Evaluating automation and vendor tools against manual processes; specific considerations for service providers

FATCA-like Obligations and Comparative Best Practices

  • Key similarities with FATCA (classification, reporting mechanics, entity and beneficiary treatment)
  • Differences to consider (scope, bilateral vs. multilateral approaches, jurisdictional variations)
  • Practical mapping exercises: adapting FATCA controls to CRS-compliant processes

Reporting, Exchange Protocols, and Audit Preparedness

  • Formats and transmission channels for CRS reports; jurisdictional submission criteria
  • Preparing for audits and regulatory reviews: 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 exception handling for complex/entity accounts
  • Remediation strategies and multi-jurisdiction coordination 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

Conclusion and Path Forward

Requirements

  • A solid grasp of financial services or compliance functions
  • Basic familiarity with tax principles and customer onboarding
  • While experience with AML/KYC processes is advantageous, it is not mandatory

Target Audience

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

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