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 Duration 14 hours

Course Outline

Introduction to CRS and International Tax Transparency

  • The origin and objectives of the CRS and the Automatic Exchange of Information (AEOI) regime
  • Identification of reporting entities: scope of Reporting Financial Institutions and reportable accounts
  • The relationship between CRS and FATCA, highlighting areas of convergence and divergence

Legal and Regulatory Landscape

  • Models for jurisdictional adoption and applicable legal frameworks (including MCAs and domestic laws)
  • Current consolidated texts and amendments affecting due diligence scopes
  • Compliance mandates, statutory deadlines, and consequences of non-adherence

Foundations of Due Diligence: Determining Tax Residency

  • Mandatory documentation: handling self-certifications and obtaining reliable documentary evidence
  • Procedures for indicia searches applicable to both new and pre-existing accounts
  • Broadening the due diligence approach by leveraging AML/KYC data to ascertain tax residence

Operational Integration: Onboarding, Data Management, and Systems

  • Embedding CRS verification steps into client onboarding and recurring review cycles
  • Essential data fields for reporting, along with strategies for maintaining data integrity and retention
  • Evaluating automation and vendor solutions against manual processes, with specific considerations for service providers

FATCA-Parallel Requirements and Comparative Best Practices

  • Commonalities with FATCA, such as entity classification, reporting mechanics, and beneficiary treatment
  • Key differences to anticipate, including scope variations and bilateral versus multilateral implementations
  • Practical mapping exercises: translating FATCA controls into CRS-compliant procedures

Reporting Mechanics, Exchange Protocols, and Audit Preparedness

  • Standard formats and transmission channels for CRS reports, alongside jurisdictional submission protocols
  • Preparing for audits and regulatory examinations: maintaining documentation, ensuring traceability, and evidencing due diligence
  • Illustrative reporting workflows and reconciliation procedures

Risk Oversight, Governance, and Internal Controls

  • Establishing governance structures, policies, and duty segregation for CRS adherence
  • Training, quality assurance, and exception management for complex and entity accounts
  • Strategies for remediating legacy accounts and coordinating across multiple jurisdictions

Practical Workshops and Case Analyses

  • Workshop: Examining and verifying sample account files and self-certifications to assess reportability
  • Workshop: Setting up a basic data extraction and reporting checklist to generate a simulated CRS XML output
  • Case study: Navigating complex entity structures, trusts, and controlling persons under CRS provisions

Conclusion and Future Directions

Requirements

  • Foundational knowledge of financial services or compliance operations
  • Basic understanding of tax principles and client onboarding processes
  • Proficiency in AML/KYC procedures is advantageous but not mandatory

Target Audience

  • Compliance professionals and legal counsel
  • Personnel responsible for onboarding, KYC, and client due diligence
  • Tax reporting and operational teams within financial organizations

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