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.
Testimonials (3)
Flexibility in the course delivery and the interactive approach. The trainer was open to questions, clarified doubts clearly and also considered participants suggestions during the sessions. The training was well structured and informative.
Soundarya Mohan - Mizuho Bank Europe N.V.
Course - Financial Analysis in Excel
Good communication, open for discussion, kept it interesting and engaging
Ahmet Keyman - Keytrade AG
Course - Management Accounting and Finance for Non-Finance Professionals
Experience of the trainer and his way of conveying the content