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 Duration 14 hours

Course Outline

Foundations of CRS and Global Tax Transparency

  • The evolution and objectives of CRS and Automatic Exchange of Information (AEOI)
  • Identifying reporting obligations: Reporting Financial Institutions and the scope of reportable accounts
  • The relationship between CRS and FATCA, highlighting areas of overlap and divergence

Legal & Regulatory Context

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

Due Diligence Essentials: Determining Tax Residency

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

Operational Implementation: Onboarding, Data Capture, and Systems

  • Embedding CRS checks into client onboarding and periodic review workflows
  • Required data elements for reporting, along with strategies for data quality and retention
  • Automation and vendor tools versus manual processes; specific considerations for service providers

FATCA-Aligned Requirements and Comparative Best Practices

  • Shared elements with FATCA (classification, reporting mechanics, entity and beneficiary treatment)
  • Distinctions to address (scope, bilateral vs. multilateral implementation, jurisdictional variations)
  • Practical mapping exercises: adapting FATCA controls to create CRS-compliant processes

Reporting, Exchange Mechanisms, and Audit Preparedness

  • CRS report formats, transmission channels, and jurisdictional submission specifics
  • Preparing for audits and regulator reviews: documentation, traceability, and due diligence evidence
  • Illustrative reporting workflows and reconciliation checks

Risk Management, Governance, and Internal Controls

  • Building governance frameworks, policies, and segregation of duties for CRS adherence
  • Training, quality assurance, and handling exceptions for complex/entity accounts
  • Remediation strategies and multi-jurisdiction coordination for legacy accounts

Hands-On Labs and Case Studies

  • Lab: Analyze and verify sample account files and self-certifications to determine reportability
  • Lab: Set up a basic data-extraction and reporting checklist; generate a mock CRS XML extract
  • Case study: Managing complex entity structures, trusts, and controlling persons under CRS rules

Recap and Future Actions

Requirements

  • A foundational understanding of financial services or compliance operations
  • Familiarity with basic tax principles and customer onboarding processes
  • Experience with AML/KYC procedures is beneficial but not mandatory

Target Audience

  • Compliance officers and legal departments
  • Onboarding, KYC, and client due diligence specialists
  • Tax reporting and operations teams within financial institutions

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