Common Reporting Standard (CRS): Compliance and Due Diligence for Financial Institutions Training Course

Introduction to CRS and Global Tax Transparency for Government

• History and purpose of the Common Reporting Standard (CRS) and Automatic Exchange of Information (AEOI)
• Entities required to report: Reporting Financial Institutions and the scope of reportable accounts
• Comparison of CRS with FATCA: Overlapping and differing requirements for government

Legal & Regulatory Framework for Government

• Jurisdictional implementation models and legal instruments (Multilateral Competent Authority Agreement, domestic legislation)
• Recent consolidated texts and amendments affecting due diligence and scope for government
• Compliance obligations, timelines, and penalties for non-compliance in a governmental context

Due Diligence Fundamentals: Identifying Tax Residency for Government

• Required documentation: Self-certifications and reliable documentary evidence for government entities
• Indicia search procedures for new and pre-existing accounts in a governmental setting
• A broader approach to due diligence, utilizing Anti-Money Laundering/Know Your Customer (AML/KYC) information to determine tax residence for government operations

Operationalizing CRS: Onboarding, Data Capture, and Systems for Government

• Integrating CRS checks into client onboarding and periodic review workflows for government agencies
• Data elements required for reporting and practical approaches to data quality and retention in a governmental context
• Using automation and vendor tools versus manual processes; considerations for service providers supporting government operations

FATCA-like Requirements and Comparative Best Practices for Government

• Key commonalities with FATCA (classification, reporting mechanics, treatment of entities and beneficiaries) in a governmental setting
• Differences to plan for (scope, bilateral vs. multilateral implementation, jurisdictional variance) for government agencies
• Practical mapping exercises: Converting FATCA controls into CRS-compliant processes for government operations

Reporting, Exchange Mechanisms, and Audit Readiness for Government

• Formats and transmission channels for CRS reports; jurisdictional submission requirements for government entities
• Preparing for audits and regulator reviews: Documentation, traceability, and evidence of due diligence in a governmental context
• Sample reporting workflows and reconciliation checks for government agencies

Risk Management, Governance, and Internal Controls for Government

• Designing governance frameworks, policies, and segregation of duties for CRS compliance in government operations
• Training, quality assurance, and exception handling for complex/entity accounts in a governmental setting
• Remediation pathways and multi-jurisdiction coordination for legacy accounts in government agencies

Practical Labs and Case Studies for Government

• Lab: Review and validate a set of sample account files and self-certifications; determine reportability for government entities
• Lab: Configure a simple data-extraction and reporting checklist; produce a mock CRS XML extract for government agencies
• Case study: Handling complex entity structures, trusts, and controlling persons under CRS rules in a governmental context

Summary and Next Steps for Government