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 Duration 14 hours

Course Outline

Introduction to CRS and Global Tax Transparency

  • The history and purpose of CRS and Automatic Exchange of Information (AEOI)
  • Identifying who must report: Reporting Financial Institutions and the scope of reportable accounts
  • The relationship between CRS and FATCA, highlighting areas of overlap and divergence

Legal & Regulatory Framework

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

Due Diligence Fundamentals: Identifying Tax Residency

  • Essential documentation: self-certifications and reliable documentary evidence
  • Indicia search procedures for both new and pre-existing accounts
  • Broader due diligence approaches and the utilization 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
  • Reporting data requirements and practical strategies for data quality and retention
  • Evaluating automation and vendor tools versus manual processes; considerations for service providers

FATCA-like Requirements and Comparative Best Practices

  • Commonalities with FATCA, such as classification, reporting mechanics, and treatment of entities and beneficiaries
  • Key differences to address, including scope, bilateral versus multilateral implementation, and jurisdictional variance
  • Practical mapping exercises: translating 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: ensuring 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 and entity accounts
  • Remediation pathways and multi-jurisdiction coordination for legacy accounts

Practical Labs and Case Studies

  • Lab: Review and validate sample account files and self-certifications to determine reportability
  • Lab: Configure a simple 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

Summary and Next Steps

Requirements

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

Target Audience

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

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