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 Duration 14 hours

Course Outline

Foundations of CRS and Global Tax Transparency

  • Origins and objectives of CRS and Automatic Exchange of Information (AEOI)
  • Reporting obligations: Financial Institutions and the scope of reportable accounts
  • The relationship between CRS and FATCA, highlighting overlaps and distinctions

Legal & Regulatory Landscape

  • Jurisdictional implementation models and legal instruments, including MCAA and domestic laws
  • Impact of recent consolidated texts and amendments on due diligence and scope
  • Compliance duties, timelines, and consequences of non-compliance

Due Diligence Essentials: Determining Tax Residency

  • Essential documentation: self-certifications and reliable documentary evidence
  • Indicia search protocols for both new and existing accounts
  • Broader due diligence strategies and leveraging AML/KYC data to establish tax residence

Operationalizing CRS: Onboarding, Data Management, and Technology

  • Embedding CRS checks into client onboarding and periodic review processes
  • Required data elements for reporting, with practical focus on data quality and retention
  • Evaluating automation and vendor tools against manual processes, including considerations for service providers

FATCA-Style Requirements and Comparative Best Practices

  • Commonalities with FATCA, such as classification, reporting mechanics, and entity/beneficiary treatment
  • Key differences to address, including scope, bilateral vs. multilateral approaches, and jurisdictional variations
  • Practical mapping exercises: adapting FATCA controls to CRS-compliant workflows

Reporting, Exchange Mechanisms, and Audit Preparedness

  • CRS report formats, transmission channels, and jurisdictional submission criteria
  • Preparing for audits and regulator reviews through documentation, traceability, and due diligence evidence
  • Sample 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 management for complex and entity accounts
  • Remediation strategies and multi-jurisdiction coordination for legacy accounts

Practical Labs and Case Studies

  • Lab: Review and verify 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: Managing complex entity structures, trusts, and controlling persons under CRS rules

Wrap-up and Future Directions

Requirements

  • A foundational grasp of financial services or compliance operations
  • Basic knowledge of tax principles and client onboarding processes
  • Previous experience with AML/KYC procedures is advantageous but not mandatory

Target Audience

  • Compliance officers and legal departments
  • Staff involved in onboarding, KYC, and client due diligence
  • Teams responsible for tax reporting and operations within financial institutions

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