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 Duration 14 hours

Course Outline

Introduction to CRS and Global Tax Transparency

  • The historical context and objectives of the CRS and Automatic Exchange of Information (AEOI).
  • Identifying Reporting Financial Institutions and defining the scope of reportable accounts.
  • Analyzing the relationship between CRS and FATCA, highlighting areas of overlap and divergence.

Legal & Regulatory Framework

  • Jurisdictional implementation models and associated legal instruments, including MCAs and domestic legislation.
  • Review of recent consolidated texts and amendments that impact due diligence scopes.
  • Understanding compliance obligations, critical timelines, and penalties associated with non-compliance.

Due Diligence Fundamentals: Identifying Tax Residency

  • Reviewing required documentation, such as self-certifications and reliable documentary evidence.
  • Conducting indicia searches for both new and pre-existing accounts.
  • Applying a broader due diligence approach that leverages AML/KYC data to determine tax residence.

Operationalizing CRS: Onboarding, Data Capture, and Systems

  • Embedding CRS checks into client onboarding and periodic review workflows.
  • Identifying necessary data elements for reporting and establishing practical approaches to data quality and retention.
  • Evaluating automation and vendor tools against manual processes, with specific considerations for service providers.

FATCA-like Requirements and Comparative Best Practices

  • Exploring key commonalities with FATCA, including classification methods, reporting mechanics, and the treatment of entities and beneficiaries.
  • Planning for differences such as scope, bilateral versus multilateral implementation, and jurisdictional variances.
  • Engaging in practical mapping exercises to translate FATCA controls into CRS-compliant processes.

Reporting, Exchange Mechanisms, and Audit Readiness

  • Examining formats and transmission channels for CRS reports, including jurisdictional submission requirements.
  • Preparing for audits and regulatory reviews through robust documentation, traceability, and evidence of due diligence.
  • Reviewing sample reporting workflows and reconciliation checks.

Risk Management, Governance, and Internal Controls

  • Designing governance frameworks, policies, and segregation of duties tailored for CRS compliance.
  • Implementing training, quality assurance, and exception handling protocols for complex entity accounts.
  • Establishing remediation pathways and multi-jurisdiction coordination strategies for legacy accounts.

Practical Labs and Case Studies

  • Lab: Review and validate a set of sample account files and self-certifications to determine reportability.
  • Lab: Configure a simple data-extraction and reporting checklist to produce a mock CRS XML extract.
  • Case study: Navigating complex entity structures, trusts, and the identification of controlling persons under CRS rules.

Summary and Next Steps

Requirements

  • A solid understanding of financial services or compliance functions.
  • Familiarity with fundamental tax concepts and customer onboarding processes.
  • Experience with AML/KYC procedures is beneficial but not mandatory.

Target Audience

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

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