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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)
  • Identification of reporting entities: Reporting Financial Institutions and the scope of reportable accounts
  • The relationship between CRS and FATCA, including overlaps and differences in requirements

Legal & Regulatory Framework

  • Jurisdictional implementation models and legal instruments (MCAA, 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

  • Necessary documentation: self-certifications and reliable documentary evidence
  • Indicia search procedures applicable to both new and pre-existing accounts
  • A broader approach to due diligence, utilizing AML/KYC information to ascertain tax residence

Operationalizing CRS: Onboarding, Data Capture, and Systems

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

FATCA-like Requirements and Comparative Best Practices

  • Key commonalities with FATCA, including classification, reporting mechanics, and the treatment of entities and beneficiaries
  • Differences requiring strategic planning, such as scope, bilateral versus multilateral implementation, and jurisdictional variations
  • Practical mapping exercises: transforming FATCA controls into CRS-compliant processes

Reporting, Exchange Mechanisms, and Audit Readiness

  • CRS report formats and transmission channels; specific jurisdictional submission requirements
  • Preparing for audits and regulator 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 or entity accounts
  • Remediation pathways and multi-jurisdiction coordination for legacy accounts

Practical Labs and Case Studies

  • Lab: Reviewing and validating sample account files and self-certifications to determine reportability
  • Lab: Configuring 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

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

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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