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 Duration 14 hours

Course Outline

Introduction to CRS and Global Tax Transparency

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

Legal & Regulatory Landscape

  • Jurisdictional implementation models and governing legal instruments, including MCAA and domestic legislation
  • Impact of recent consolidated texts and amendments on due diligence and scope
  • Compliance mandates, regulatory timelines, and penalties associated with non-adherence

Due Diligence Fundamentals: Determining Tax Residency

  • Essential documentation requirements, encompassing self-certifications and reliable documentary evidence
  • Procedures for indicia searches applicable to both new and pre-existing accounts
  • Broader due diligence strategies utilizing AML and KYC data to ascertain tax residence

Operationalizing CRS: Onboarding, Data Capture, and Systems

  • Integration of CRS checks into client onboarding and periodic review workflows
  • Required data elements for reporting, along with practical strategies for data quality and retention
  • Evaluation of automation and vendor tools versus manual processes, with specific 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
  • Notable differences to address, such as scope, bilateral versus multilateral implementation, and jurisdictional variations
  • Practical mapping exercises to transition FATCA controls into CRS-compliant processes

Reporting, Exchange Mechanisms, and Audit Readiness

  • Reporting formats and transmission channels; specific jurisdictional submission requirements
  • Strategies for audit and regulator review preparation, focusing on documentation, traceability, and due diligence evidence
  • Illustrative reporting workflows and reconciliation verification steps

Risk Management, Governance, and Internal Controls

  • Development of governance frameworks, policies, and segregation of duties protocols for CRS compliance
  • Implementation of training, quality assurance, and exception handling procedures for complex and entity accounts
  • Remediation strategies and multi-jurisdiction coordination for legacy account management

Practical Labs and Case Studies

  • Lab: Examine and validate a selection of sample account files and self-certifications to determine reportability
  • Lab: Establish a basic data extraction and reporting checklist; generate a mock CRS XML extract
  • Case study: Navigating complex entity structures, trusts, and controlling persons under CRS regulations

Conclusion and Future Directions

Requirements

  • A foundational understanding of financial services or compliance functions
  • Familiarity with basic tax concepts and customer onboarding processes
  • Exposure to AML and KYC processes is advantageous but not mandatory

Audience

  • Compliance officers and legal teams
  • Professionals in onboarding, KYC, and client due diligence
  • Tax reporting and operations teams within financial institutions

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