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Course Outline

Introduction to CRS and Global Tax Transparency

  • The history and objectives of the CRS and the Automatic Exchange of Information (AEOI) framework.
  • Identification of reporting entities: 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 legal instruments, including the Multilateral Competent Authority Agreement (MCAA) and domestic legislation.
  • Updates to consolidated texts and amendments affecting due diligence scope.
  • Compliance obligations, implementation timelines, and penalties for non-compliance.

Due Diligence Fundamentals: Identifying Tax Residency

  • Required documentation, including self-certifications and reliable documentary evidence.
  • Indicia search procedures for both new and pre-existing accounts.
  • Adopting a broader approach to due diligence by leveraging AML/KYC information to determine tax residence.

Operationalizing CRS: Onboarding, Data Capture, and Systems

  • Integrating CRS checks into client onboarding and periodic review workflows.
  • Identifying required data elements for reporting and strategies for ensuring data quality and retention.
  • Evaluating the use of automation and vendor tools versus manual processes, with considerations for service providers.

FATCA-like Requirements and Comparative Best Practices

  • Key similarities with FATCA, including classification, reporting mechanics, and the treatment of entities and beneficiaries.
  • Key differences to anticipate, such as scope, bilateral versus multilateral implementation, and jurisdictional variations.
  • Practical mapping exercises for translating 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 comprehensive 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 to support CRS compliance.
  • Implementing training, quality assurance, and exception handling protocols for complex accounts and entities.
  • Establishing remediation pathways and coordinating across jurisdictions 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 and produce 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 procedures.
  • Previous experience with AML/KYC processes is advantageous but not mandatory.

Target Audience

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

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