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 Duration 14 hours

Course Outline

Introduction to CRS and Global Tax Transparency

  • The history and objectives of the CRS and Automatic Exchange of Information (AEOI)
  • Identifying Reporting Financial Institutions and the scope of reportable accounts
  • The relationship between CRS and FATCA, highlighting overlapping and distinct requirements

Legal & Regulatory Framework

  • Jurisdictional implementation models and associated legal instruments (MCAA, domestic laws)
  • Recent consolidated texts and amendments affecting due diligence and scope
  • Compliance duties, timelines, and penalties for non-adherence

Due Diligence Fundamentals: Identifying Tax Residency

  • Necessary documentation, including self-certifications and reliable documentary evidence
  • Indicia search procedures for both new and pre-existing accounts
  • A broader due diligence approach leveraging AML/KYC data to determine tax residence

Operationalizing CRS: Onboarding, Data Capture, and Systems

  • Integrating CRS checks into client onboarding and periodic review processes
  • Data elements required for reporting, along with practical strategies for data quality and retention
  • Assessing automation and vendor tools against manual processes, with considerations for service providers

FATCA-like Requirements and Comparative Best Practices

  • Commonalities with FATCA, including classification, reporting mechanics, and entity/beneficiary treatment
  • Key differences to consider, such as scope, bilateral versus multilateral implementation, and jurisdictional variations
  • Practical mapping exercises: adapting FATCA controls into CRS-compliant processes

Reporting, Exchange Mechanisms, and Audit Readiness

  • Formats and transmission channels for CRS reports, along with jurisdictional submission requirements
  • Preparing for audits and regulatory reviews through documentation, traceability, and evidence of due diligence
  • Sample reporting workflows and reconciliation checks

Risk Management, Governance, and Internal Controls

  • Developing governance frameworks, policies, and segregation of duties for CRS compliance
  • Training, quality assurance, and exception handling for complex and entity accounts
  • Remediation strategies 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 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

Summary and Next Steps

Requirements

  • A solid grasp of financial services or compliance functions
  • Knowledge of 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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